ESG funds can be used for day shelters that meet the criteria under the emergency shelter definition in section 576.2, which provides:   "Emergency shelter means any facility, the primary purpose of which is to provide a temporary shelter for the homeless in general or for specific populations of the homeless and which does not require occupants to sign leases or occupancy agreements. Any project funded as an emergency shelter under a Fiscal...
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ESG funds can be used for day shelters that meet the criteria under the emergency shelter definition in section 576.2, which provides:  

"Emergency shelter means any facility, the primary purpose of which is to provide a temporary shelter for the homeless in general or for specific populations of the homeless and which does not require occupants to sign leases or occupancy agreements. Any project funded as an emergency shelter under a Fiscal Year 2010 Emergency [Shelter] grant may continue to be funded under ESG."

According to this criteria, if the day shelter’s primary purpose is to provide temporary shelter for the homeless in general or specific subpopulations of the homeless, and the day shelter does not require occupants to sign leases or occupancy agreements, then the day shelter meets the emergency shelter definition and may be funded as an emergency shelter under ESG.  Also, the primary purpose must be evident in the shelter’s features; at a minimum, homeless people must be able to stay in the facility for as many hours as it is open. 

In addition, for a day shelter to use ESG funds to serve people as an emergency shelter, the facility must follow the requirements that apply to ESG recipients and subrecipients with respect to those funds and activities.  For example:

• Each client must be homeless, and must be evaluated for eligibility and assistance needed.  This evaluation must be conducted in accordance with 24 CFR § 576.401(a);
• Each client’s eligibility and homeless status must be documented in accordance with the requirements in 24 CFR § 576.500(b);
• Client and activity data must be entered into the local HMIS.  This must be completed in accordance with the requirements in 24 CFR § 576.400(f); and
• The shelter must follow the written standards (required under 24 CFR § 576.400(e)) related to emergency shelters and essential services, including: 

(1) Policies and procedures for admission, diversion, referral, and discharge by emergency shelters assisted under ESG, including standards regarding length of stay, if any, and safeguards to meet the safety and shelter needs of special populations, e.g., victims of domestic violence, dating violence, sexual assault, and stalking; and individuals and families who have the highest barriers to housing and are likely to be homeless the longest; and

(2) Policies and procedures for assessing, prioritizing, and reassessing individuals' and families' needs for essential services related to emergency shelter.

Note: If a shelter serves both eligible and ineligible clients under ESG, then the shelter’s eligible costs must be allocated in proportion to “the relative benefits received,” as set forth in the OMB Cost Principles. For more information about this, please see OMB Circular A-122: http://www.whitehouse.gov/omb/circulars_a122_2004

The following DO NOT qualify as eligible emergency shelters for ESG:

• A doctor’s office or other facility where a person can only stay for the time of his/her appointment;
• Multi-purpose service centers serving all people in need; or
• Stand-alone food pantries/soup kitchens/cafeterias.

Communities should fund activities in day shelters that are targeted to people who are sleeping on the streets or in emergency shelter.

Note also that the costs of services such as case management and mental health services provided to homeless persons in the shelter would be eligible under essential services, as long as the costs comply with the rule (see 24 CFR § 576.100(d) and § 576.102, especially).  The costs of providing laundry facilities or meals in the shelter would be eligible under shelter operations, as long as the costs comply with the rule (see 24 CFR § 576.100(d) and 576.102, especially).

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ESG funds may be used for:  Providing essential services to homeless families and individuals in emergency shelters;  Renovating buildings to be used as emergency shelter for homeless families and individuals; and  Operating emergency shelters. Because these costs are focused on emergency shelter, a transitional facility will only be eligible to receive ESG funds for these costs if:  1. It meets BOTH of the following criteri...
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ESG funds may be used for: 

1. Providing essential services to homeless families and individuals in emergency shelters; 
2. Renovating buildings to be used as emergency shelter for homeless families and individuals; and 
3. Operating emergency shelters.

Because these costs are focused on emergency shelter, a transitional facility will only be eligible to receive ESG funds for these costs if: 

1. It meets BOTH of the following criteria under the new emergency shelter definition: 

• Its primary purpose is to provide a temporary shelter for the homeless in general or for specific populations of the homeless; and 
• It does not require occupants to sign leases or occupancy agreements; 

OR

2. It received funds under a FY 2010 Emergency Shelter Grants grant and met the criteria under the former emergency shelter definition (“any facility, the primary purpose of which is to provide temporary or transitional shelter for the homeless in general or for specific populations of the homeless”).

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Employee compensation (including fringe benefits such as holiday, vacation, sick leave) and other overhead costs directly related to carrying out activities eligible under an ESG component are eligible costs under that component (see 24 CFR § 576.100(d)). Determining how these staff costs should be allocated will depend on the type of assistance being provided to the program participant. To allocate these costs, first determine the program compo...
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Employee compensation (including fringe benefits such as holiday, vacation, sick leave) and other overhead costs directly related to carrying out activities eligible under an ESG component are eligible costs under that component (see 24 CFR § 576.100(d)). Determining how these staff costs should be allocated will depend on the type of assistance being provided to the program participant.

To allocate these costs, first determine the program component under which these costs fall; then allocate the costs to an activity within the component. For example, staff time expended on processing checks for utility payments for program participants could be eligible under the rapid re-housing component or the homelessness prevention component; the activity would be housing relocation and stabilization services.

For the salaries and related costs of staff that are not fully dedicated to a particular component, costs should be reimbursed in proportion to the actual hours worked on each ESG component. A staff position that is not fully dedicated to ESG cannot be paid solely through ESG funds.

For example, if an accountant spends 100 percent of his/her time tracking rental assistance or security deposits for homelessness prevention activities, then paying for this time is allowable under the homelessness prevention component because the accountant's time is only spent working on a single component. Alternatively, the cost for an accountant to process checks for both the homelessness prevention and rapid re-housing components must be pro-rated by each component. Also, the accountant's time preparing an invoice to obtain ESG funds from the recipient (or, for a recipient, a staff member's time drawing funds in IDIS) would be an administrative cost. Therefore, recipients or subrecipients must break out the accountant's time based on the activities performed.

Other overhead costs, such as rent for office space, photocopier costs, and lighting and utilities for an office, could be eligible either as a direct cost charged to one or more components, depending on the activities delivered by that office, or could be charged as an indirect cost if part of an indirect cost allocation plan.

Additionally, please be aware of the following:

• If any of these cost items is part of an indirect cost allocation plan, they must not be billed directly to any activity.
• If costs are related to planning and executing the ESG program but are not attributable to ESG activities under a specific component, they may be charged as administrative activities. Please review 24 CFR part 576.108 for additional detail. 
• When more than one ESG component or other programs are operated from the same office, the costs and the rationale used to determine the portion of the costs assigned to each component and/or program must be carefully documented.

In terms of how to track staff time, the exact methodology for tracking the time that staff worked on federal grants, and on components and activities within a federal grant, is at the discretion of the recipient. However, recipients and subrecipients must be able to sufficiently document the actual time charged to federal grants and the methodology used, which must be reasonable and justifiable. The OMB guidance does not require that recipients track actual time by ESG component and activity, but there must be a methodology in place to estimate time allocated to components because of the statutory caps in place on street outreach and emergency shelter, and administration. Additionally, because of the CAPER reporting requirements, there must be a methodology in place to estimate time allocated to activities within a component. While actual time is preferred, any estimates must be a realistic reflection of actual time spent across ESG components and activities.

Timesheets that capture actual time spent on specific programs are the most straightforward way to meet time reporting requirements. However, other approaches may be acceptable as long as they meet the guidelines established in Circular A-87 Appendix B(8)(H) for States or units of local government or Circular A-122 Appendix B(8)(m) for nonprofit organizations, or the OMB OmniCircular, at 2 CFR part 200, as applicable. 

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Yes, recipients and subrecipients may procure services from any organization, including for-profit organizations, as long as recipients follow 24 CFR § 85.36, and nonprofit subrecipients follow 24 CFR § 84.40 – 84.48. For example, a shelter may use ESG operating costs to pay for trash removal by a for-profit business.

Financial and Grants Management - General

The Housing Opportunity Through Modernization Act of 2016, Public Law 114-201 (HOTMA) amended the McKinney-Vento Homeless Assistance Act to permit units of general purpose local government to sub-award their ESG funds to Public Housing Agencies (PHAs) and Local Redevelopment Authorities (LRAs). The statutory authority to sub-award Emergency Solutions Grants (ESG) Program funds to a PHA or LRA applies to all ESG Program grant funds, including fund...
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The Housing Opportunity Through Modernization Act of 2016, Public Law 114-201 (HOTMA) amended the McKinney-Vento Homeless Assistance Act to permit units of general purpose local government to sub-award their ESG funds to Public Housing Agencies (PHAs) and Local Redevelopment Authorities (LRAs). The statutory authority to sub-award Emergency Solutions Grants (ESG) Program funds to a PHA or LRA applies to all ESG Program grant funds, including funds awarded before HOTMA was enacted. However, this authorization is subject to certain conditions and requirements, as explained in Notice CPD-17-10: Sub-awarding Emergency Solutions Grants Program Funds to Public Housing Agencies and Local Redevelopment Authorities.

Here are some key points from the Notice:

• ESG Program Grants to Metropolitan Cities and Urban Counties. The HOTMA amendment provides explicit authority to local governments to sub-award funds to PHAs and LRAs. Any local government that receives an ESG Program grant from HUD or receives ESG Program funds from an urban county as a member government may sub-award all or a portion of those funds to a PHA or LRA, subject to the requirements described in section IV of Notice CPD-17-10.
• ESG Program Grants to States. The HOTMA amendment does not authorize States to directly sub-award ESG funds to PHAs or LRAs. However, subject to the ESG requirements, any local government that receives ESG Program funds from a State may sub-award such funds to a PHA or LRA under the conditions described in section IV of Notice CPD-17-10. As a result of changes previously made by the Moving Ahead for Progress in the 21st Century (MAP-21) Act, Public Law No. 112-141 (2012), a State may sub-award to an LRA if the LRA is an instrumentality of a unit of general purpose local government, other than a PHA, that is established pursuant to legislation and designated by the chief executive to act on behalf of the local government with regard to ESG activities.
• Private Nonprofit Organizations. Private nonprofit organizations that receive ESG Program funds as subrecipients are prohibited from sub-awarding ESG Program funds to PHAs or LRAs.

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Actual time must be charged to federal grants. The exact methodology for tracking the time that staff worked on federal grants and on components within a federal grant is at the discretion of the recipient. However, recipients and subrecipients must be able to justify and document the methodology used, and it must be reasonable and well-documented. The OMB Circulars do not require that recipients track actual time by ESG component, but there must...
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Actual time must be charged to federal grants. The exact methodology for tracking the time that staff worked on federal grants and on components within a federal grant is at the discretion of the recipient. However, recipients and subrecipients must be able to justify and document the methodology used, and it must be reasonable and well-documented. The OMB Circulars do not require that recipients track actual time by ESG component, but there must be a methodology in place to estimate time allocated to components because of the statutory caps in place on the Street Outreach and Emergency Shelter components, and Administration activities. While actual time is preferred, any estimates must be a realistic reflection of actual time spent across ESG components.

Timesheets that capture actual time spent on specific programs are the most straightforward way to meet time reporting requirements. However, other approaches may be acceptable as long as they meet the guidelines established in Circular A-87 Appendix B(8)(H) for States or units of local government or Circular A-122 Appendix B(8)(m) for nonprofit organizations.

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Timesheets that capture actual time spent on specific programs are the most straightforward way to meet time reporting requirements. However, other approaches may be acceptable as long as they meet the guidelines established in Circular A-87 Appendix B(8)(H) for States or units of local government or Circular A-122 Appendix B(8)(m) for nonprofit organizations.

Invoicing/processing payments

Recipients have two years from the date HUD signed the grant agreement to expend all ESG funds. Per 24 CFR 576.203(b), “expended” means that all eligible costs must be incurred by that date. Recipients may draw down funds after the 2-year expenditure deadline for eligible expenses incurred before that date.

Obligation and Expenditure

An inclusive and responsive coordinated entry (CE) process for all youth can only be achieved through widespread stakeholder participation in planning and implementing CE. To ensure that the CE process incorporates the needs of youth, the planning and implementation process needs to include: Youth experiencing homelessness; Youth homeless assistance providers including those funded by the Runaway and Homeless Youth Act; Child welfare systems and...
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An inclusive and responsive coordinated entry (CE) process for all youth can only be achieved through widespread stakeholder participation in planning and implementing CE. To ensure that the CE process incorporates the needs of youth, the planning and implementation process needs to include:

• Youth experiencing homelessness;
• Youth homeless assistance providers including those funded by the Runaway and Homeless Youth Act;
• Child welfare systems and their providers including independent living programs;
• School district McKinney-Vento liaisons;
• Representatives from the juvenile and adult justice systems;
• Employment programs;
• Human trafficking providers;
• Law enforcement;
• Health providers;
• Out-of-school time programs; and
• Early childhood providers for pregnant and parenting youth.

Early and ongoing participation by these organizations in communities that have successfully integrated youth experiencing homelessness into their CE processes is credited with building trust in CE for youth-serving providers and other key stakeholders, and with sharing critical knowledge among youth and non-youth stakeholders that has ensured the entire process is youth-appropriate. Continuums of Care (CoCs) should also consider taking inventory of local youth resources beyond traditional homelessness housing and services as there may be more youth resources available to the community than the CoC realizes, including family reunification services and youth homelessness prevention services.

Many stakeholders may not be solely focused on youth homelessness, but will still play an important role. Stakeholders such as child welfare agencies, school district McKinney-Vento liaisons, and juvenile justice programs should be key partners in the development of CE, and once implemented, their roles within the CE process will vary widely based on the program’s specific interactions with youth and the programs’ specific population focus. The key is to generate a mutual understanding between CoCs and community stakeholders early on regarding how youth access CE from non-homelessness dedicated programs and how these programs' resources are accessed by youth through the CE process. In general, programs and system partners will fall into three categories:

• Programs that can connect youth to the CE process - Programs that ask basic questions about housing status and have a protocol for connecting youth to the CE process when a housing or homelessness service need is identified that cannot be provided by the provider or program. These programs may vary greatly in their capacity to connect youth. For example, a program may have limited capacity to add questions to their intake and use a single indicator or observation to trigger a phone call to the CE access point. Another program may have extensive capacity to identify youth experiencing homelessness and at-risk youth and so may ask a series of questions concerning housing status to increase their referral accuracy to the CE process, which is made electronically and seamlessly.
   
• Programs to which the CE process connects youth - Programs that offer resources that are relevant for youth experiencing homelessness and for whom a protocol has been established to connect youth from CE to the intake process for those resources. Programs will vary in their capacity to make themselves available to the CE process. Some may have a simple protocol that allows for a coordinated connection from CE to their services, whether through an electronic connection or even a warm hand off made with the help of staff navigators. Another program with a lot of flexibility may be able to co-locate programming with CE operations ensuring youth can go through the referral and intake process for their services at the same location and time as they go through the CE process.
   
• Programs that are fully integrated into the CE process - Programs that are fully integrated into the CE process where they either participate as an access point for all CE resources or their resources are accessed directly through CE referrals without an additional intake. Full integration for mainstream services will be rare as their expanded population focus and mission often makes full integration burdensome for both parties; although in some circumstances and in some communities it may still be appropriate.

Involving systems and programs that serve youth early in the development process of CE and in an ongoing manner is the best way to ensure that these partners are both identifying and referring youth from their programs to the CE process and that CE process is able to refer to their programs when appropriate.

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No - HUD is not currently requiring reports for coordinated entry. However, HUD is working on guidance specific to coordinated entry and HMIS for both project set-up and reporting, which it will issue in the near future. Communities should ensure that their HMIS is programmed to the 2014 HMIS Data Standards.

Coordinated Entry

Yes - However, it is important to note that data collected for assessment—which could be as simple as scores from assessment tools or something more complex—is not necessarily the same as data collected for HMIS. To the extent that the data overlaps and if your CoC plans to import the data into the HMIS at any point, the CoC must ensure that the module meets all HMIS data and technical standards (i.e., the data collected complies with th...
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Yes - However, it is important to note that data collected for assessment—which could be as simple as scores from assessment tools or something more complex—is not necessarily the same as data collected for HMIS. To the extent that the data overlaps and if your CoC plans to import the data into the HMIS at any point, the CoC must ensure that the module meets all HMIS data and technical standards (i.e., the data collected complies with the 2014 HMIS Data Standards, HUD security policies, and meets any other requirements).

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No - HUD does not require CoCs to use their HMIS as part of their coordinated entry process. However, many communities recognize the benefit of using this option and have incorporated HMIS into their coordinated entry process. HUD is encouraging communities to consider using HMIS but recognizes that other systems might be better or more quickly able to meet the community’s coordinated entry needs, which is acceptable so long as the co...
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No - HUD does not require CoCs to use their HMIS as part of their coordinated entry process. However, many communities recognize the benefit of using this option and have incorporated HMIS into their coordinated entry process. HUD is encouraging communities to consider using HMIS but recognizes that other systems might be better or more quickly able to meet the community’s coordinated entry needs, which is acceptable so long as the community’s coordinated entry meets HUD’s requirements in 24 CFR 578.7(a)(8).

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Depends - HUD recognizes that many HMIS implementations are closed and do not share data across providers. While it is possible to use a closed HMIS as a tool in your coordinated entry process, functionality will vary by system. Your organization should work with the HMIS Lead and HMIS vendor to determine if using the HMIS for the coordinated entry process is possible in your community.

Coordinated Entry

Yes - HMIS funds in the CoC and ESG Programs may be used to pay for coordinated entry, but only to the extent that the coordinated entry is integrated in the CoC’s HMIS. Per 24 CFR 576.107(a)(2) and 24 CFR 578.57(b) HMIS Leads may use funds to pay to customize or enhance the CoC’s HMIS to integrate coordinated entry. Additionally, per 24 CFR 576.107(a)(1) and 24 CFR 578.57(a), all recipients and subrecipients contributing data to the HMIS may...
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Yes - HMIS funds in the CoC and ESG Programs may be used to pay for coordinated entry, but only to the extent that the coordinated entry is integrated in the CoC’s HMIS. Per 24 CFR 576.107(a)(2) and 24 CFR 578.57(b) HMIS Leads may use funds to pay to customize or enhance the CoC’s HMIS to integrate coordinated entry. Additionally, per 24 CFR 576.107(a)(1) and 24 CFR 578.57(a), all recipients and subrecipients contributing data to the HMIS may use funds to pay for entering data into an HMIS that is also used for coordinated entry.

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The primary purpose of the coordinated entry (CE) standardized assessment process is to gather information necessary to determine the severity of a youth’s needs and their eligibility for housing and services in a way that utilizes their strengths and is based on evidence of the risk of becoming or remaining homeless. The CE assessment should gather information on factors that can help systems prevent youth from experiencing homelessness or end...
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The primary purpose of the coordinated entry (CE) standardized assessment process is to gather information necessary to determine the severity of a youth’s needs and their eligibility for housing and services in a way that utilizes their strengths and is based on evidence of the risk of becoming or remaining homeless. The CE assessment should gather information on factors that can help systems prevent youth from experiencing homelessness or end their current homelessness experience as quickly as possible. This is in contrast to a clinical assessment common within the youth-serving field that looks at more in-depth service needs on an ongoing basis throughout a youth’s involvement in the homelessness system. The CE standardized assessment may be a phased assessment utilizing more than one assessment tool, allowing the assessment process to occur over time and only as necessary. For example, a standardized screening and assessment process may have separate tools to:

• Screen for diversion or prevention (such as supportive services, early intervention, and family reunification support)
   
• Assess shelter and other emergency needs
   
• Identify housing and service resources and barriers
   
• Evaluate vulnerability to prioritize for assistance (which may include evaluating risk and protective factors to make placements as effective as possible)
   
• Screen for program eligibility
   
• Facilitate connections to mainstream resources (including adult resources when appropriate)

The CE assessment will likely occur over a period of days or weeks, as needed, depending on the progress a youth experiencing homelessness is making. The different assessments build on each other so a participant does not have to repeat their story. Periodic ongoing assessment should occur to ensure interventions are meeting a youth’s needs, particularly if a youth remains homeless for a long period of time. Federal partners are working together to release more detailed guidance later in 2016 on the use of youth screening and assessment tools within the CE process that can help guide placement decisions for housing and services.

Once youth receive a housing and service intervention through CE, a service provider may assess for additional or more intensive service needs on an ongoing basis while youth are being served in the youth homelessness system. Utilizing screening and assessment is equally as important after a youth has entered into a homelessness program in order to determine if the placement and services are meeting youth needs, or to determine if the youth needs other types of interventions and services.

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Yes. In many situations, family reunification is an appropriate referral within coordinated entry (CE), provided that the family home is a safe and stable environment. Family reunification should be a primary referral option for youth under 18, where only a small percentage may be most appropriately served by an independent, safe, and stable housing situation, and many youth 18 and older will also benefit from family reunification services. The C...
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Yes. In many situations, family reunification is an appropriate referral within coordinated entry (CE), provided that the family home is a safe and stable environment. Family reunification should be a primary referral option for youth under 18, where only a small percentage may be most appropriately served by an independent, safe, and stable housing situation, and many youth 18 and older will also benefit from family reunification services. The CE assessment process should consider family dynamics and the possibility of youth reuniting with family members or caring adults in a safe and stable environment; and “family” options should be broadly defined to include adults who may not be biological parents or biologically related, but whom youth consider to be family members. The CE process should also have access to family reunification service referral options, including non-HUD funded projects, for those youth who are identified as having the potential of returning home before entering the crisis response system or who may quickly exit with the assistance of family interventions. The need for access to family reunification and a broad array of family engagement services in the community is another example of why it is important for the CE process to be linked to mainstream services and other non-HUD funded services.

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RHY programs, whether they are funded federally or privately, are an integral part of many communities’ efforts to prevent and end homelessness. It is therefore vitally important for all RHY providers to be integrated into their community’s Continuum of Care (CoC), to be at the table to provide input, and to help ensure that the coordinated entry (CE) process is fully responsive to the needs of youth experiencing homelessness. In addition to ...
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RHY programs, whether they are funded federally or privately, are an integral part of many communities’ efforts to prevent and end homelessness. It is therefore vitally important for all RHY providers to be integrated into their community’s Continuum of Care (CoC), to be at the table to provide input, and to help ensure that the coordinated entry (CE) process is fully responsive to the needs of youth experiencing homelessness.

In addition to their experience working with youth experiencing homelessness in their respective programs, RHY providers bring with them a wealth of knowledge about the network of social, behavioral health, and other community services vital to ensuring youth experiencing homelessness are able to transition to stability and independence. Because of this specialized knowledge and experience, RHY providers should be involved in general needs assessment planning committees, in addition to the planning, development, and implementation of the CE process. RHY providers should fully participate in: 1) the decision-making process to identify access procedures and locations; 2) designing and informing youth-appropriate screening and assessment tools and related staff training; 3) the development of the prioritization process to ensure vulnerable youth have access to resources; and 4) the development of the referral process, particularly around matching youth needs and strengths to appropriate housing and services.

RHY providers contribute invaluable homelessness prevention and intervention resources to the community through the Basic Center, Transitional Living, Maternity Group Home, and Street Outreach Programs. RHY resources should be fully integrated in the implementation of the CE process by aligning their access, assessment, and prioritization processes with the policies and procedures developed by the full community of stakeholders through CE. Integrating RHY resources is critical to creating a single CE process for youth experiencing homelessness. Beyond the specific CE process, RHY providers can continue to help ensure that resources offered to youth are developmentally appropriate, promote positive youth development, incorporate trauma-informed care, and are culturally and linguistically competent. Federal partners are working together to release more detailed guidance later in 2016 on the important role of RHY providers in the CE process.

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Under current regulations, coordinated entry (CE), at a minimum, must serve youth defined as homeless and at-risk of homelessness by HUD. However, HUD and HHS strongly encourage communities to also include youth considered homeless or runaway by other federal definitions*. The CE process will encounter youth when they are in various stages of experiencing a housing-related crisis and should be designed to accommodate a broad range of youth who ar...
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Under current regulations, coordinated entry (CE), at a minimum, must serve youth defined as homeless and at-risk of homelessness by HUD. However, HUD and HHS strongly encourage communities to also include youth considered homeless or runaway by other federal definitions*. The CE process will encounter youth when they are in various stages of experiencing a housing-related crisis and should be designed to accommodate a broad range of youth who are experiencing homelessness, have runaway, and who are at-risk of homelessness. Through the CE process, Continuums of Care (CoCs) can coordinate non HUD-funded housing and supportive services, as well as HUD-funded Emergency Solutions Grants (ESG) and non-homelessness dedicated HUD programs that may be able to serve those youths who are considered “homeless,” “runaway,” or “at-risk” by other federal definitions. It is important for CoCs to work towards building a broad range of resources that include homelessness prevention, family interventions, an array of housing interventions that include supportive services, and connections to mainstream resources in order to best serve a broad range of youth who are experiencing homelessness, have runaway, and are at-risk of homelessness. The inclusion of a broad range of stakeholders in the CoC, and the implementation and development of the CE process, will help ensure this goal is met.

When working with the broad range of youth, communities may pay particular attention to the unique needs of vulnerable subpopulations including youth who are either overrepresented in the unaccompanied homeless youth population or are particularly vulnerable to the effects of homelessness, such as:

• Youth under the age of 18
• Pregnant and parenting youth
• Youth involved or formerly involved in the child welfare system
• Youth involved or formerly involved in the juvenile justice system
• Youth fleeing or attempting to flee from trafficking or other unsafe living environments
• Youth who identify as lesbian, gay, bisexual, transgender, or questioning (LGBTQ)
• Native American youth
• Youth with special needs or disabilities, including severe behavioral and mental health needs
• Youth who are sharing the housing of others due to loss of housing or economic hardship
• Youth who have run away from home without parental consent
• Youth of color

Coordination with non-youth partners is critical when considering subpopulation approaches as their resource and support needs overlap with non-youth specific providers. For example, pregnant and parenting youth should have access to and may be better served by family-specific resources and youth fleeing unsafe situations may be better served by domestic violence or trafficking-specific resources.

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*View the Definition of Runaway and Homeless Youth as defined by the Runaway and Homeless Youth Act. View the Definition of Homeless Children and Youths as defined by Subtitle VII-B of the McKinney-Vento Homeless Assistance Act.

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Regardless of whether it is through a youth-specific coordinated entry (CE) process or a single CE process serving all populations, including youth, there are critical youth factors for communities to consider when developing a CE process to ensure it is appropriate for youth. Several of these considerations are: Youth-Centered: The CE process should be built on relationships between adults and youth that are empowering to youth and based on pos...
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Regardless of whether it is through a youth-specific coordinated entry (CE) process or a single CE process serving all populations, including youth, there are critical youth factors for communities to consider when developing a CE process to ensure it is appropriate for youth. Several of these considerations are:

• Youth-Centered: The CE process should be built on relationships between adults and youth that are empowering to youth and based on positive youth development principles.
   
• Safe, Inviting, and Accessible Access Points: Access point locations–physical and virtual–should be safe, inviting, and easily accessible for youth, taking into account where youth congregate and other important aspects of local youth culture. Continuums of Care (CoCs) must decide whether they will operate a youth-specific access point for CE with dedicated and specially trained staff or make sure that all general access points have the cultural and linguistic competency to meet youth needs. The important decisions involved in establishing access points highlight why a broad range of stakeholders, including youth providers, should be involved in the CoC and in the planning and implementation of the CE process.
   
• Comprised of Knowledgeable and Trained Staff: Any staff involved in the CE process who will interact with youth – whether at a standalone access point, emergency shelter, or through street outreach – should be adequately trained, meaning they are knowledgeable about topics such as, developmentally appropriate solutions, the eligibility and documentation requirements for the dedicated homeless resources and applicable mainstream resources available through a referral from the CE process.
   
• Developmentally-Appropriate and Trauma-Informed: The CE process and those working directly with youth should be aware of youth brain development, positive youth development frameworks, and trauma frameworks in order to ensure that the CE process as a whole is developmentally appropriate and trauma informed.
   
• Culturally-Appropriate and Inclusive: The CE process, including any assessment tool used with youth, should be responsive to the characteristics and needs of youth, including age, race, ethnicity, sexual orientation, gender identification, and language. The definition of “culturally appropriate” for all youth includes youth who have been victims of human trafficking or domestic violence, LGBTQ youth, and pregnant or parenting youth.
   
• Built on Provider Expertise and Capacity: The CE process for youth should be informed by the expertise and capacity of all youth-serving providers and organizations in a community. Stakeholder engagement in the development, implementation, and process improvement of CE is critical for success.
   
• Informed by the Youth Intervention Model: The CE process, should be grounded in risk and protective factors as noted in the USICH Youth Framework’s Preliminary Intervention Model.

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In order to ensure that youth are referred to appropriate housing and services, a broad array of youth focused housing and services need to be included among all of the resources available to the coordinated entry (CE) process. Youth who have been assessed for housing and services need to know exactly which program they are being referred to, what will be expected of them, and what they should expect from the program. Providers and caseworkers kn...
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In order to ensure that youth are referred to appropriate housing and services, a broad array of youth focused housing and services need to be included among all of the resources available to the coordinated entry (CE) process. Youth who have been assessed for housing and services need to know exactly which program they are being referred to, what will be expected of them, and what they should expect from the program. Providers and caseworkers knowledgeable of a youth’s experiences should provide input on referrals most appropriate for their developmental stage, needs, and strengths, through processes such as case conferencing. The CE process should also incorporate individual project eligibility requirements and current availability because project participants must be eligible for the projects to which they are referred, and the participants may need to meet additional project-specific eligibility requirements that are independent of the assessment and prioritization process. For example, a transitional housing project may be funded to serve individuals with HIV/AIDS. In order for the dedicated project to accept the youth being referred, the youth must meet the priority population that the project is funded to serve, in addition to being prioritized for the type of resource through the CE process. Armed with the best available information, youth can make an informed and supported choice to enroll in their preferred intervention among a comprehensive array of available options that address their needs and for which they are eligible.

CE referrals may occur throughout a young person’s involvement with the homelessness system, usually connected with ongoing assessment. For example, a youth living on the streets may be connected to emergency shelter after an initial triage interaction with a street outreach worker. The youth may receive a more comprehensive assessment once in shelter, and based on the prioritization process described in FAQ 2933, be referred to an intervention that can help to resolve their homelessness, such as family reunification, transitional living programs, rapid re-housing, or other placements and supportive services. Additional referrals may occur after a young person begins participation in a homelessness program if they need additional or different housing and supports to address their homelessness, and may include connections to mainstream services.

HUD and the U.S. Department of Health and Human Services (HHS) acknowledge that the description above for a youth-focused CE process has not been fully realized by many communities and that communities are in different stages of planning and implementing youth processes in their CE. The hope is that these FAQs, as well as upcoming detailed guidance and technical assistance, will enable communities to develop a more robust CE process that is responsive to the needs and strengths of homeless youth and is inclusive of all youth providers.

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Prioritization ensures that youth with the most severe service needs and levels of vulnerability are prioritized for limited housing and homeless assistance resources that meet their needs and strengths and is the process by which a youth is placed in a relative order for referral to different types of housing and services. As discussed in FAQ 2940, runaway and homeless youth (RHY) and other youth providers should play an active role in the Conti...
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Prioritization ensures that youth with the most severe service needs and levels of vulnerability are prioritized for limited housing and homeless assistance resources that meet their needs and strengths and is the process by which a youth is placed in a relative order for referral to different types of housing and services. As discussed in FAQ 2940, runaway and homeless youth (RHY) and other youth providers should play an active role in the Continuum of Care’s (CoC) development of the prioritization process to ensure vulnerable youth have access to resources. Prioritization principles must be consistently applied and may reflect the following vulnerability factors:

• Significant health or behavioral health challenges or functional impairments which require a significant level of support in order to maintain permanent housing;
   
• High utilization of crisis or emergency services, including emergency rooms, jails, and psychiatric facilities to meet basic needs;
   
• The extent to which people, especially youth and children, are unsheltered;
   
• Vulnerability to illness or death;
   
• Risk of continued homelessness;
   
• Vulnerability to victimization, including physical assault, trafficking, or sex work; or
   
• Other factors determined by the community and based on severity of needs.

Assessment tools will capture some of these factors and yield an “assessment score.” The other factors identified by the community, including those that account for the unique experiences and vulnerabilities of youth, will be combined with the assessment score to determine a prioritization “ranking” for housing and services. It is important to note that the “ranking” does not necessarily equal the “assessment score” produced by popular assessment tools. CoCs can choose to prioritize a certain vulnerability factor over another, which would allow an individual to be placed at a higher priority for the next available and appropriate resource than their assessment score dictates. For example, a pregnant or parenting youth might have a moderate risk and vulnerability “assessment score” based on the assessment tools used in the community, but their CoC may determine that all pregnant and parenting youth should be considered at higher risk. Therefore, a pregnant or parenting youth in that community with only a moderate assessment score would be ranked as a higher priority for the next available, appropriate resource. If a youth meets multiple factors prioritized by the community (e.g. a youth is pregnant or parenting, has serious behavioral health needs, and is fleeing domestic violence), the multiple vulnerabilities should contribute to a higher prioritization ranking than if the youth only meets a single factor prioritized by the community. These examples emphasize the importance of setting priorities that consider the vulnerabilities of youth and the limitations of assessment tools. Prioritization ranking must ensure that coordinated entry (CE) prioritizes youth for housing and supportive services when they meet the factors prioritized by the community, even when assessment scores do not indicate a relatively high risk.

Communities should incorporate processes to connect youth who are not ranked high enough for a dedicated homelessness resource to other types of resources in the community. Referrals to services not targeted exclusively to homeless and runaway youth should include family counseling, community-based mental health services, Temporary Assistance to Needy Families (TANF), early childhood supports, education-based supports, and other mainstream services that may be able to help address youths’ needs. RHY providers have experience in making these types of youth-appropriate referrals and links, and can help CoCs develop methods that ensure these types of connections are made through the CE process. Finally, the prioritization process should not limit access to emergency services such as HUD funded emergency shelter or RHY Basic Center Programs, and every attempt should be made to ensure that young people are off the streets as quickly as possible.

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There are several models for access points which include, but are not limited to, the following: “Single point of access” at one central community location, sometimes referred to as centralized intake;   “Multisite centralized access” at several locations in a community, sometimes referred to as hubs or a hybrid approach, that can serve all or certain special populations;   “No wrong door” available on location at any commu...
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There are several models for access points which include, but are not limited to, the following:

• “Single point of access” at one central community location, sometimes referred to as centralized intake;
   
• “Multisite centralized access” at several locations in a community, sometimes referred to as hubs or a hybrid approach, that can serve all or certain special populations;
   
• “No wrong door” available on location at any community provider but still standardized and coordinated through one community-wide process; and
   
• “Virtual or phone access” which allows for mobile access (e.g. 2-1-1, mobile app) to CE and can be combined with any of the processes above.

Youth providers and other community partners can work with their local Continuum of Care (CoC) to serve as an access point in any one of the above models, helping to ensure youth access in a space or manner that is culturally and developmentally appropriate for youth. In communities where a youth provider may not serve as an access point, they can still be an important partner in planning for the most appropriate access point or points for youth in their community.

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A coordinated entry (CE) process standardizes and coordinates the way youth access the community’s homelessness crisis response system and connect with the appropriate resources they need to achieve safety and stability. The process should ensure that youth receive the housing and service supports they need to resolve their homelessness crisis as quickly as possible, with the lowest possible barriers. The CE process should be able to answer the...
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A coordinated entry (CE) process standardizes and coordinates the way youth access the community’s homelessness crisis response system and connect with the appropriate resources they need to achieve safety and stability. The process should ensure that youth receive the housing and service supports they need to resolve their homelessness crisis as quickly as possible, with the lowest possible barriers. The CE process should be able to answer the homeless system’s guiding question, “Which housing and supportive services best meet the needs of each youth?” The core elements of this process include (1) access, (2) screening and assessment for housing and services, (3) prioritization, and (4) referral, and should be developed by each Continuum of Care (CoC) through a community-wide planning process.

View a chart of the guiding question, “Which housing and supportive services best meet the needs of each youth?” and its four key elements.

• Step 1: Standardized access: Ensures all youth seeking access to their community’s homelessness system engage the system through the same coordinated and standardized process regardless of where or how they present for services.
• Step 2: Standardized screening and assessment: Uses a standardized approach for all youth presenting for homelessness assistance to gather information on factors that can prevent and end their homelessness and inform the types of services and housing that meet their needs and strengths.
• Step 3: Standardized prioritization: Ensures that youth with the most severe service needs and levels of vulnerability are prioritized for limited housing and other non-emergency homelessness assistance resources (does not include emergency shelter, basic centers, street outreach, etc.) that meet their needs.
• Step 4: Coordinated referral: Ensures that youth can be referred to any homelessness dedicated housing and services for which they qualify and are prioritized for across the entire community.

For a more detailed explanation of the core elements of a CE process please refer to HUD’s Coordinated Entry Policy Brief and to HUD’s CoC 2.0 Training Material – Coordinated Assessment.

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Yes. As described in the February 2015 HUD Coordinated Entry Policy Brief, it may be appropriate, though not required, for communities to establish processes, “including different access points and screening and assessment tools,” for four specific groups only: Youth;   Families;   Individuals; and   Victims of Domestic Violence (including trafficked youth, victims of other forms of abuse and exploitation, and youth fleeing or...
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Yes. As described in the February 2015 HUD Coordinated Entry Policy Brief, it may be appropriate, though not required, for communities to establish processes, “including different access points and screening and assessment tools,” for four specific groups only:

1. Youth;
    
2. Families;
    
3. Individuals; and
    
4. Victims of Domestic Violence (including trafficked youth, victims of other forms of abuse and exploitation, and youth fleeing or attempting to flee abuse and exploitation).

Continuums of Care (CoCs) are not required to have separate processes and there are many good reasons based on a community’s geographic size, population, characteristics of the local crisis response system, etc., for choosing single or separate processes. However, HUD and the U.S. Department of Health and Human Services (HHS) both recognize that the cultural competencies, resources, safety protocols, service models, and rules and regulations are different enough for these populations that having separate processes may be necessary. For example, youth may have a separate access point, dedicated staff to conduct assessments, special questions and protocols, and a unique prioritization system that accounts for the differences in the experiences of homelessness for youth versus adults. Separate CE processes should be accounted for in the CoC’s policies and procedures related to CE, be consistently implemented across each of the four permissible subpopulations, and follow the community’s established assessment guidelines.

It is important for all subpopulation-specific systems to align their access and referral processes to account for the significant overlap between populations being served and the resources that should be available to them. For instance, while CE may primarily refer youth to youth-specific resources, there are typically additional non-youth-specific resources to which youth experiencing homelessness should have access. These resources include mainstream services aimed at a broader population than youth and housing interventions that may not specifically target youth, but from which some youth may still benefit. Similarly, a community with a process for families and a separate process for youth needs to be aware that young families may need to access both youth- and family-appropriate housing and services without having to go through two separate processes. Most importantly, the CE process should be developed with the full participation of all stakeholders so that the entire process is appropriate for the full breadth of populations.

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Federal partners have recently identified coordinated entry (CE) as a key component of the coordinated community response to prevent and end youth homelessness in 2020. CE is also required for all housing programs receiving HUD Continuum of Care (CoC) and Emergency Solutions Grants (ESG) funding and strongly recommended for all of a community’s homelessness-dedicated resources. In order for these community-wide processes to appropriately serve ...
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Federal partners have recently identified coordinated entry (CE) as a key component of the coordinated community response to prevent and end youth homelessness in 2020. CE is also required for all housing programs receiving HUD Continuum of Care (CoC) and Emergency Solutions Grants (ESG) funding and strongly recommended for all of a community’s homelessness-dedicated resources. In order for these community-wide processes to appropriately serve youth, CoCs need to address the developmental and service needs of unaccompanied homeless youth and ensure that all community stakeholders, including Runaway and Homeless Youth (RHY) providers, child welfare agencies, school systems, systems of justice, workforce systems partners, and other youth-serving organizations, come together for both the planning and implementation of a youth-inclusive CE process.

A youth-inclusive CE process requires CoCs to implement a systems-level, youth-focused approach for youth access, screening and assessment*, prioritization, and referral to housing and supportive services. The intent of CE is to standardize and streamline the process for youth access to homelessness-dedicated resources across the entire homelessness crisis response system, and to lower the overall burden on youth to receive needed housing and supportive services. This process allows a CoC to make decisions based on the availability of resources across an entire community, not just at an individual program or project, expanding a youth’s access to needed community resources. Youth should also be screened and assessed with the same standardized, culturally competent tools as their peers, regardless of who the assessor may be, and expect to be referred according to the same prioritization factors that are used for all youth in the community. An effective, youth-centered process also reduces the number of interviews that require repeating highly personal information, often involving traumatic experiences, and reduces the amount of time it takes to receive housing and supportive services.

Included in the CE process is the implementation of an initial housing-focused assessment of youth needs and strengths, which is used in conjunction with a process (which may be specific to youth) to prioritize housing and supportive services in a timely manner. Prioritization helps to ensure that the highest need, most vulnerable youth, with the most risk factors and fewest protective factors across the community, are prioritized for housing services (see FAQ 2934 for what “Assessment” means in the CE context and FAQ 2935 for more detail on prioritization factors for vulnerable youth and the preliminary intervention model of the Federal Framework to End Youth Homelessness). Prioritization is critical because the homelessness crisis response system for youth is under-resourced and CoCs need to make tough decisions around prioritizing limited homelessness-dedicated housing and services. The tough decisions that a CoC must make around prioritization are a prime example of why it is critical for a broad set of community stakeholders to be actively involved in the CoC and in the design and implementation of CE.

It is important to note that HUD and the U.S. Department of Health and Human Services (HHS) believe that no individual should have to sleep on the streets. Therefore, the CE process should never be a barrier to accessing emergency services, such as emergency shelter, respite, and crisis residential assistance. Communities should work to ensure that all individuals seeking emergency services have access to those services without barriers.

The CE process also gives a community a more complete and up-to-date vacancy, turn-away, and overall utilization picture that allows community planners to make better decisions about resource allocation and funding requests. More accurate, research-informed placements and refined pathways to well-coordinated housing and services can reduce burden and redundancies and connect youth experiencing homelessness to mainstream services. The CE development and feedback processes have the potential to serve as a powerful vehicle for additional youth systems-building and innovative collaboration in the community. CE can give your community the power to make more efficient use of the beds and services currently available and the data to argue for new targeted resources.

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*The terms screening and assessment are being used in this document in a few different ways. In the context of CE, the terms screening and assessment involve tools that specifically measure an individual’s vulnerability to harm and continued homelessness and need for housing and related services. In contrast, behavioral assessment follows behavioral screening if the screening results are positive for a particular behavior or symptom. Ongoing assessment can occur both for behavioral services, such as mental health or addiction services, and for other types of services and supports, such as more intensive rental assistance, throughout a youth’s involvement in the homelessness system.

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Although HUD does not endorse or require the use of any specific assessment form, tool, or approach, it has described some universal qualities that should be incorporated into any form, tool, or approach used by a Continuum of Care (CoC) for its coordinated entry process. See HUD’s Coordinated Entry Policy Brief for a full description of these qualities and criteria. HUD recognizes the need for further guidance as both the process and the tools...
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Although HUD does not endorse or require the use of any specific assessment form, tool, or approach, it has described some universal qualities that should be incorporated into any form, tool, or approach used by a Continuum of Care (CoC) for its coordinated entry process. See HUD’s Coordinated Entry Policy Brief for a full description of these qualities and criteria.

HUD recognizes the need for further guidance as both the process and the tools continue to evolve; therefore, some of the qualities reflected in the Coordinated Entry Policy Brief may be modified over time to reflect HUD’s evolving understanding of the assessment process and what is determined to be most effective. In February, 2015, HUD released a brief, “Assessment Tools for Allocating Homeless Assistance: State of the Evidence,” which summarizes the observations of a panel of experts on existing assessment tools that are being used by communities to allocate homeless assistance, and considers the evidence base for the questions included in the tools. The brief provides helpful context concerning what we know about the power and limitations of assessment tools currently available for communities to employ.

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If the Continuum of Care (CoC) chooses to create a separate coordinated entry process for people fleeing domestic violence, including separate access points, that process must be developed in coordination with local victim service providers, adhere to the same requirements as the broader coordinated entry process, and be designed according to the qualities outlined in the Coordinated Entry Policy Brief, with the only difference being that it is t...
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If the Continuum of Care (CoC) chooses to create a separate coordinated entry process for people fleeing domestic violence, including separate access points, that process must be developed in coordination with local victim service providers, adhere to the same requirements as the broader coordinated entry process, and be designed according to the qualities outlined in the Coordinated Entry Policy Brief, with the only difference being that it is targeted to individuals and families fleeing domestic violence. Any separate process must ensure that victims of domestic violence have equal access to homeless services and housing programs that are provided to those using the primary access point. One promising practice is to use a virtual domestic violence access point. Virtual access points include internet and phone-based systems (e.g. 211) that can quickly be accessed from any location where the household seeking assistance feels safe.

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Continuums of Care (CoCs) will find the victim service providers and state domestic and sexual violence coalitions in their communities to be excellent resources in developing a coordinated entry process that has protocols in place to ensure the safety of the individuals seeking assistance. CoCs should engage with these organizations as well as other experienced stakeholders and providers to determine the best options for victims fleeing domestic...
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Continuums of Care (CoCs) will find the victim service providers and state domestic and sexual violence coalitions in their communities to be excellent resources in developing a coordinated entry process that has protocols in place to ensure the safety of the individuals seeking assistance. CoCs should engage with these organizations as well as other experienced stakeholders and providers to determine the best options for victims fleeing domestic violence. Protocols to protect the safety of households seeking assistance should be in place for every phase of the coordinated entry process, including addressing safety concerns associated with the coordinated entry access point(s).

Communities may choose to use the same coordinated entry access point or points for all populations or may choose to establish a separate access point or points for households fleeing domestic violence. Similarly, the domestic violence access point(s) can be one or more physical location or virtual, such as a 211 line. Each scenario requires different protocols to ensure safety. For instance, if using a common access point that has a physical location, assessment staff should treat all persons presenting for assistance with strict confidentiality and privacy, conducting their assessments out of sight and ear shot of other persons at the physical location. If using a separate access point for households fleeing domestic violence, that access point should be a virtual or phone-based access point to protect the household’s physical safety. Communities should strongly consider using a local domestic violence hotline as an access point, even if other access points are available, to ensure the safety of households fleeing domestic violence. In all cases, whether a common access point or a separate access point is used to assess victims of domestic violence, data must be collected in accordance with the confidentiality requirements established in the CoC and Emergency Solutions Grants (ESG) Program interim rules (24 CFR 578.103(b) and 24 CFR 576.500(x)) and data collected by a victim service provider must be collected in accordance with the Violence Against Women Act (VAWA), which prohibits victim service providers from entering client-level data into HMIS.

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Domestic violence is often very traumatic for households, including children exposed to domestic violence. It is imperative that coordinated entry processes be designed to prevent further trauma and to provide households with control over the process and referrals. Trauma-informed practices that are sensitive to the lived experience of all people presenting for services need to be incorporated into every aspect of the coordinated entry process. T...
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Domestic violence is often very traumatic for households, including children exposed to domestic violence. It is imperative that coordinated entry processes be designed to prevent further trauma and to provide households with control over the process and referrals. Trauma-informed practices that are sensitive to the lived experience of all people presenting for services need to be incorporated into every aspect of the coordinated entry process. The assessment tool and process should not re-traumatize the individual or family, must inform the person up-front about how the information will be used, and must allow them the option to refuse to answer questions or choose not to disclose personal information.

The coordinated entry process must also include protocols to ensure the safety of all individuals and families seeking assistance, and these protocols must specifically address how individuals and families fleeing domestic violence will have safe and confidential access to the coordinated entry process along with safe and secure referrals to appropriate housing and services. Further, the process must include procedures for how referrals will be made to victim service providers that are not participating in the coordinated entry process. CoCs should work with victim service providers in their community to determine the most appropriate procedures to implement.

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Individuals and families fleeing or healing from domestic violence or trauma should have access to the full range of housing and service intervention options available in their community, including prevention, diversion, rapid re-housing, and other housing and mainstream services. However, special consideration must be given to their unique and often complex physical and emotional safety needs. In particular, they might benefit from participation...
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Individuals and families fleeing or healing from domestic violence or trauma should have access to the full range of housing and service intervention options available in their community, including prevention, diversion, rapid re-housing, and other housing and mainstream services. However, special consideration must be given to their unique and often complex physical and emotional safety needs. In particular, they might benefit from participation in housing programs that offer trauma-informed and culturally-relevant services.

All coordinated entry staff should be trained on the complex dynamics of domestic violence, privacy and confidentiality, and safety planning, including how to handle emergency situations at an access point(s), whether a physical or virtual location. Continuums of Care (CoCs) should also partner with their local victim service provider agencies to ensure that trainings for relevant staff are provided by informed experts in the field of domestic violence, dating violence, sexual assault, stalking, and human trafficking. If a household is determined to be at risk of harm when an assessment is being conducted, then the coordinated entry staff should refer the household to a victim service provider using referral criteria established for that community based on system design, program capacity, resource limitations, and placement and geography considerations. The coordinated entry process should also have a procedure to safely refer the household to the identified victim service provider, preferably with a warm hand-off including a phone call, transportation, or other transition to the victim service provider. Communities should consult with their local victim service providers or state coalitions against domestic violence to develop models for building a quality assessment process, including screening questions around domestic and sexual violence. Finally, coordinated entry staff should have up-to-date information on domestic violence shelters and general homeless shelters and housing options that are best equipped to serve households experiencing domestic violence based on their location, program model, and linkages to other supportive services.

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Yes - HUD allows and actively promotes the full participation and integration of victim service providers into the Continuum of Care (CoC) coordinated entry process. The form this integration takes will vary by community, but the overarching goal is for individuals and families presenting to the homeless and victim services system to have full and complete access to the housing and service resources available through both systems. Specifical...
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Yes - HUD allows and actively promotes the full participation and integration of victim service providers into the Continuum of Care (CoC) coordinated entry process. The form this integration takes will vary by community, but the overarching goal is for individuals and families presenting to the homeless and victim services system to have full and complete access to the housing and service resources available through both systems. Specifically, HUD encourages CoCs to work with victim service providers within the CoC’s geographic area to establish client-driven, trauma-informed and culturally-relevant assessment and screening tools, as well as referral policies and procedures, to ensure that the coordinated entry process addresses the physical and emotional safety, and privacy and confidentiality needs of participants. This includes separate access points, if necessary and appropriate, and access to all available and appropriate housing options and related supportive services, regardless of whether the individual or family presents for intake at a victim services access point or at a more general access point.

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HUD defines a victim service provider to mean a private nonprofit organization whose primary mission is to provide direct services to victims of domestic violence. This term includes permanent housing providers—including rapid re-housing, domestic violence programs (shelters and non-residential), domestic violence transitional housing programs, dual domestic violence and sexual assault programs, and related advocacy and supportive services programs.

Coordinated Entry

Yes - While victim service providers are prohibited from entering personally identifying information into HMIS, HUD is encouraging CoCs to work with their victim services providers to establish either a process for their participation in the CoC’s coordinated entry process or establish their own coordinated entry process outside of the HMIS. It is important that this process provides access to all available housing and services regardless of wh...
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Yes - While victim service providers are prohibited from entering personally identifying information into HMIS, HUD is encouraging CoCs to work with their victim services providers to establish either a process for their participation in the CoC’s coordinated entry process or establish their own coordinated entry process outside of the HMIS. It is important that this process provides access to all available housing and services regardless of whether the individual or family presents for intake at a victim-specific access point or a mainstream homeless service access point.

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Yes - All households, regardless of their domestic violence (DV) status, have the right to refuse to share their information among providers within the Continuum of Care (CoC). In fact, all service providers are prohibited from denying assistance to program applicants and program participants if they refuse to permit the provider to share their information with other providers. However, some information may be required by the project, or by publi...
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Yes - All households, regardless of their domestic violence (DV) status, have the right to refuse to share their information among providers within the Continuum of Care (CoC). In fact, all service providers are prohibited from denying assistance to program applicants and program participants if they refuse to permit the provider to share their information with other providers. However, some information may be required by the project, or by public or private funders to determine eligibility for housing or services, or to assess needed services, so it must be collected. In cases where a client does not consent to having their information shared, the information must still be collected by the service providers to determine whether the individual or family is eligible, but it must not be shared via the HMIS if the program participant objects. For instance, if a provider needs to verify the presence of a disability in the process of determining eligibility for Permanent Supportive Housing (PSH), the information itself must be collected but not shared via HMIS.

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Yes, as long as they meet all of the other requirements of category 2 of the homeless definition. The second category of the definition of homeless includes individuals and families who are within 14 days of losing their housing, including housing they own, rent, are sharing with others, or are living in without paying rent. It also includes individuals and families who are living in hotels and motels that they are paying for using their own reso...
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Yes, as long as they meet all of the other requirements of category 2 of the homeless definition. The second category of the definition of homeless includes individuals and families who are within 14 days of losing their housing, including housing they own, rent, are sharing with others, or are living in without paying rent. It also includes individuals and families who are living in hotels and motels that they are paying for using their own resources.  

Any individual or family who will lose their housing within 14 days – including those who are within one week of losing their housing – who have not identified a subsequent residence, and who lack the resources or support networks needed to obtain other permanent housing, qualifies as “homeless” under category 2 of the homeless definition.

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The regulatory text found on page 76016 and page 76019 contain the correct requirements. These sections indicate that acceptable evidence of a disability includes: Written verification of the disability from a professional licensed by the state to diagnose and treat the disability and his or her certification that the disability is expected to be long-continuing or of indefinite duration and substantially impedes the individual’s ability to li...
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The regulatory text found on page 76016 and page 76019 contain the correct requirements. These sections indicate that acceptable evidence of a disability includes:

• Written verification of the disability from a professional licensed by the state to diagnose and treat the disability and his or her certification that the disability is expected to be long-continuing or of indefinite duration and substantially impedes the individual’s ability to live independently; OR
• Written verification from the Social Security Administration; OR
• The receipt of a disability check; OR
• Intake staff-recorded observation of a disability that, no later than 45 days of the application for assistance, is confirmed and accompanied by evidence in this; OR
• Other documentation approve by HUD.

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No. Youth who are within 14 days of exiting the foster care system who have not identified other permanent housing and who have no other resources or support networks to obtain permanent housing are not defined as homeless under Category 2 of the definition of homeless. This is different than how HUD operationalized eligibility for Transitional Housing and Supportive Service Only projects under the Supportive Housing Program. The HEARTH...
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No. Youth who are within 14 days of exiting the foster care system who have not identified other permanent housing and who have no other resources or support networks to obtain permanent housing are not defined as homeless under Category 2 of the definition of homeless. This is different than how HUD operationalized eligibility for Transitional Housing and Supportive Service Only projects under the Supportive Housing Program.

The HEARTH Act amendments changed the definition of homeless for HUD’s Homeless Assistance programs and HUD began implementing the changes through the FY2011 Homeless Assistance Grants Program competition. In most instances, the definition was broadened; however, in this one instance, the definition was narrowed.

The statutory language in Section 103(5), which HUD further clarified through the regulations, defines as homeless, “An individual who resided in a shelter or place not meant for human habitation and who is exiting an institution where he or she temporarily resided.”  Through the regulation, HUD further clarified that individuals exiting systems of care, including institutions and foster care, are no longer defined as homeless if they have resided there for more than 90 days and were not previously living on the streets or in emergency shelter prior to entering the institution or system of care. This means that unaccompanied youth being emancipated from the foster care system are not defined as homeless under Category 1, unless they are residing on the streets or in an emergency shelter at the point of intake.

Additionally, HUD has determined that individuals exiting institutions, or systems of care, are not defined as homeless under paragraph (2) of the definition of homeless even if they are within 14-days of discharge an no subsequent residence has been identified. This means that unaccompanied youth who are being emancipated from the foster care system are not defined as homeless under Category 2, and are therefore not eligible for those projects that serve Category 2 in the CoC Program.

These youth, however, may be defined as Category 3 of the homeless definition if the following conditions are met:

• The youth is under the age of 25
• The youth meets another federal definition of homeless
• The youth has not had a lease, ownership interest, or occupancy agreement in permanent housing during the 60 days prior to the homeless assistance application
• The youth has experienced persistent instability as measured by two moves or more during the preceding 60 days
• The youth can be expected to continue in such status for an extended period of time due to special needs or barriers

A youth who is defined as homeless under Category 3 of the homeless definition may only be eligible for transitional housing if the CoC has received approval from HUD to serve this population. If the youth does not meet criteria described above, then he or she could be considered at-risk of homelessness. To meet the “at-risk of homelessness” definition, an individual must have an annual income below 30 percent of the median family income for the area, as determined by HUD, not have sufficient resources or support networks to prevent him or her from moving to an emergency shelter or other place not intended as a regular sleeping accommodation for human beings, and is exiting a publicly funded institution, or system of care (such as a mental health facility). A person who is defined as "at risk of homelessness" may be eligible for a homelessness prevention program under the Emergency Solutions Grants program.

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Yes. Program participants that are receiving Rapid Re-Housing Assistance through programs such as the Emergency Solutions Grants (ESG) Program, the Continuum of Care (CoC) Program, the Supportive Services for Veterans Families (SSVF) Program, or the Veterans Homelessness Prevention Demonstration Program (VHPD) maintain their chronically homeless status for the purpose of eligibility for other permanent housing programs dedicated to serving the ch...
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Yes. Program participants that are receiving Rapid Re-Housing Assistance through programs such as the Emergency Solutions Grants (ESG) Program, the Continuum of Care (CoC) Program, the Supportive Services for Veterans Families (SSVF) Program, or the Veterans Homelessness Prevention Demonstration Program (VHPD) maintain their chronically homeless status for the purpose of eligibility for other permanent housing programs dedicated to serving the chronically homeless, such as HUD-VASH and CoC-funded permanent supportive housing (so long as they meet any other additional eligibility criteria for these programs). Program participants maintain their chronically homeless status during the time period that they are receiving the rapid re-housing assistance. Rapid re-housing is a model for helping homeless individuals and families obtain and maintain permanent housing, and it can be appropriate to use as a bridge to other permanent housing programs.

It is important to note that although the program participants in rapid re-housing are considered chronically homeless for purposes of eligibility for other programs, the housing itself is still considered permanent housing; therefore, these program participants are not considered chronically homeless (or homeless) for counting purposes, and must not be included in the CoC's sheltered point-in-time count.

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Yes. Program participants that are receiving Rapid Re-Housing Assistance through programs such as the Emergency Solutions Grants (ESG) Program, the Continuum of Care (CoC) Program, the Supportive Services for Veterans Families (SSVF) Program, or the Veterans Homelessness Prevention Demonstration Program (VHPD) maintain their homeless status for the purpose of eligibility for other permanent housing programs, such as HUD-VASH and CoC-funded perman...
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Yes. Program participants that are receiving Rapid Re-Housing Assistance through programs such as the Emergency Solutions Grants (ESG) Program, the Continuum of Care (CoC) Program, the Supportive Services for Veterans Families (SSVF) Program, or the Veterans Homelessness Prevention Demonstration Program (VHPD) maintain their homeless status for the purpose of eligibility for other permanent housing programs, such as HUD-VASH and CoC-funded permanent supportive housing (so long as they meet any other additional eligibility criteria for these programs). Program participants only maintain their homeless status during the time period that they are receiving the rapid re-housing assistance. Rapid re-housing is a model for helping homeless individuals and families obtain and maintain permanent housing, and it can be appropriate to use as a bridge to other permanent housing programs.

It is important to note that although the program participants in rapid re-housing are considered homeless for purposes of eligibility for other programs, the housing itself is still considered permanent housing; therefore, these program participants are not considered homeless for counting purposes, and must not be included in the CoC's sheltered point-in-time count.

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If a program participant leaves the program but remains in the unit for which the deposits were paid, the landlord will continue to hold the security deposit as provided in the lease, and the utility company will continue to hold any utility deposit as provided in the utility contract. The terms of the lease and state or local law will dictate what the landlord may do with the security deposit when the tenant leaves the unit. And the terms o...
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If a program participant leaves the program but remains in the unit for which the deposits were paid, the landlord will continue to hold the security deposit as provided in the lease, and the utility company will continue to hold any utility deposit as provided in the utility contract. The terms of the lease and state or local law will dictate what the landlord may do with the security deposit when the tenant leaves the unit. And the terms of the utility contract and state or local law will dictate what the utility company may do with the utility deposit when the utility contract terminates.

The ESG interim rule does not require security or utility deposits to be returned to the program either when the program participant leaves the program or when the lease or utility contract terminates. ESG recipients may establish their own policies regarding security and utility deposit repayments to the extent allowable under state and local law. However, any repayment of a security or utility deposit to the recipient or subrecipient (or contractor of the recipient or subrecipient) is program income under 24 CFR 576.2, must be used as match in accordance with 24 CFR 576.201, and must be tracked in accordance with the recordkeeping requirements for match and program income under 24 CFR 576.500(o) and 576.500(u)(3).

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Homeowners who meet ESG eligibility criteria may, under certain circumstances, receive utility payment assistance to cover the costs of utilities in the home that the individual/family owns.   While recipients can provide utility-only assistance, HUD expects that this will be rare. First, there are laws governing public utilities in many states that prevent utility companies from shutting off power to households during winter months and that...
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Homeowners who meet ESG eligibility criteria may, under certain circumstances, receive utility payment assistance to cover the costs of utilities in the home that the individual/family owns.
 
While recipients can provide utility-only assistance, HUD expects that this will be rare. First, there are laws governing public utilities in many states that prevent utility companies from shutting off power to households during winter months and that may also require the utility company to offer payment plans to households that miss payments. Second, there may be other forms of utility assistance available to prevent utility shut-off, such as LIHEAP.
 
If staff confirms that neither of these conditions exists, however, utility-only assistance may be justified under certain circumstances. If the household is going to have to leave the housing due to a lack of utilities, can avoid literal homelessness by having utilities paid, and meets other ESG eligibility requirements explained below, then a household may be assisted under the Homelessness Prevention component with utility-only assistance.
 
Please note that in order for a household to be eligible for financial assistance under the Homelessness Prevention component, individuals or families must meet the criteria under the "at risk of homelessness" definition, or the criteria in paragraph 2, 3, or 4 (where the household does not also meet paragraph 1) of the "homeless" definition, AND have an annual income below 30 percent of the median family income for the area, as determined by HUD, at initial evaluation (§ 576.103). In some cases, these criteria include determining at intake whether an individual or family lacks the resources to retain permanent housing or obtain other permanent housing.
 
Finally, ESG is not intended to be simply an eviction prevention program; it is intended to be a part of a system-wide approach. In order to evaluate and coordinate services to the greatest extent possible, the ESG Interim Rule requires the following:

• Every ESG program participant must be connected to mainstream and other resources as needed, as stated in § 576.401(d);
• Each program participant must receive housing stability case management, including meeting with a case manager and developing a plan to assist the program participant to retain permanent housing after the ESG assistance ends, as stated in § 576.401(e);
• ESG recipients must have written policies and procedures for coordination among different providers of services in the community - activities must be coordinated and integrated to the maximum extent practicable, as stated in § 576.400(e)(3)(v)).

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No, ESG funds cannot be used to pay for mortgage payments.

Eligible Activities/Uses

ESG funds may not be used to pay for a program participant's vehicle registration or gas for a program participant's vehicle so that he/she may transport belongings to the new unit. However, the cost of gas could be covered for moving expenses, under § 576.105(a)(6)), if the ESG recipient or subrecipient is using its organization's vehicle or a moving van to assist a program participant in his/her move.

Eligible Activities/Uses

Yes. Section 576.100(d) of the Emergency Solutions Grants (ESG) Program Interim Rule allows recipients or subrecipients to charge staff and overhead costs directly related to carrying out street outreach, emergency shelter, homelessness prevention, rapid re-housing, and HMIS as eligible costs of those program components. This means that to the extent staff need to be trained on how to work with individuals who may have contracted the virus or pre...
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Yes. Section 576.100(d) of the Emergency Solutions Grants (ESG) Program Interim Rule allows recipients or subrecipients to charge staff and overhead costs directly related to carrying out street outreach, emergency shelter, homelessness prevention, rapid re-housing, and HMIS as eligible costs of those program components. This means that to the extent staff need to be trained on how to work with individuals who may have contracted the virus or prevent the spread of COVID-19, the costs for training those staff can be charged to the budget line item of the staff member's duties. For example, in an emergency shelter that receives funding for case management and trains case managers on how to identify if someone may have contracted the virus and maintain their own safety in their interactions, the cost of training can be charged to the emergency shelter – essential services activity.

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Housing providers (e.g. landlords) may not charge fees for service animals, beyond a standard fee or security deposit that applies to all tenants who do not have pets. Therefore, ESG funds may not be used for this type of expense. If the service animal causes damage to a unit or a common area, the landlord or service provider may charge the tenant a fee to cover the damages (for damage costs above the amount covered by the security deposit), as l...
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Housing providers (e.g. landlords) may not charge fees for service animals, beyond a standard fee or security deposit that applies to all tenants who do not have pets. Therefore, ESG funds may not be used for this type of expense. If the service animal causes damage to a unit or a common area, the landlord or service provider may charge the tenant a fee to cover the damages (for damage costs above the amount covered by the security deposit), as long as the landlord complies with their standard policies and fees, but ESG funds may not be used to pay for damage costs outside of the security deposit.

For more information on the regulations surrounding service animals, please review the Joint Statement on Reasonable Accommodations under the Fair Housing Act, which covers pet fees/deposits on page 9.

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Holistic case management for persons experiencing homelessness or at risk of homelessness is not housing counseling as defined in the Housing Counseling: New Certification Requirements Final Rule (“Final Rule”). Therefore, if an activity provided under the ESG program is part of holistic case management for persons experiencing homelessness or at risk of homelessness, it is not housing counseling and certification is not required. However, th...
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Holistic case management for persons experiencing homelessness or at risk of homelessness is not housing counseling as defined in the Housing Counseling: New Certification Requirements Final Rule (“Final Rule”). Therefore, if an activity provided under the ESG program is part of holistic case management for persons experiencing homelessness or at risk of homelessness, it is not housing counseling and certification is not required. However, there may be instances where housing counseling, as defined in the Final Rule, is being provided under the ESG program. For example, if a program participant is receiving housing counseling, as defined in the Final Rule, as a separate specialized service, then the housing counseling has to be provided by a HUD certified housing counselor working for an agency approved to participate in HUD’s Housing Counseling Program, as of August 1, 2021, the Final Compliance Date. The Final Rule defines housing counseling as:

“Independent, expert advice customized to the need of the consumer to address the consumers’ housing barriers and achieve their housing goals and must include the following process: intake; financial and housing affordability analysis; an action plan, except for reverse mortgage counseling; and a reasonable effort to have follow-up communication with the client when possible. The content and process of housing counseling must meet the standards outlined in the regulations that govern HUD’s Housing Counseling Program including but not limited to 24 CFR Part 5, 24 CFR Part 214, and HUD Handbook 7610.1REV 5. Homeownership counseling and rental counseling are types of Housing Counseling.”

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Housing counseling is an eligible activity under the ESG program. If a recipient or subrecipient chooses to fund housing counseling, as defined in the Housing Counseling: New Certification Requirements Final Rule, under their program, the housing counseling must be provided by HUD certified housing counselors working for an agency approved to participate in HUD’s Housing Counseling Program, by the Final Compliance Date....
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Housing counseling is an eligible activity under the ESG program. If a recipient or subrecipient chooses to fund housing counseling, as defined in the Housing Counseling: New Certification Requirements Final Rule, under their program, the housing counseling must be provided by HUD certified housing counselors working for an agency approved to participate in HUD’s Housing Counseling Program, by the Final Compliance Date.

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Under HUD's Homeless Assistance Programs, persons presenting together for assistance regardless of marital status, actual or perceived sexual orientation, or gender identity are considered a family and can be served as a family in the ESG and CoC programs. In general, when determining the homeless status of families where the individual members are not residing together when they present for intake into the project (e.g. one parent is staying in ...
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Under HUD's Homeless Assistance Programs, persons presenting together for assistance regardless of marital status, actual or perceived sexual orientation, or gender identity are considered a family and can be served as a family in the ESG and CoC programs.

In general, when determining the homeless status of families where the individual members are not residing together when they present for intake into the project (e.g. one parent is staying in an emergency shelter and the other parent is staying with a child at a friend’s house), eligibility must be assessed using:

1. The adult head of household (in cases where more than one adult is present in the family, HUD allows the family to choose which adult will be the head of household, for application purposes); or
    
2. The minor head of household when no adult is present.

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Whether a recipient/subrecipient must stop a program participant’s ESG assistance upon learning of an increase in income (or other change in household circumstances that may affect eligibility) depends upon whether the information is obtained through a re-evaluation, or through other means (e.g., case management).  If income over AMI is discovered during re-evaluation for homelessness prevention and rapid re-housing assistance:  Each ...
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Whether a recipient/subrecipient must stop a program participant’s ESG assistance upon learning of an increase in income (or other change in household circumstances that may affect eligibility) depends upon whether the information is obtained through a re-evaluation, or through other means (e.g., case management). 

If income over AMI is discovered during re-evaluation for homelessness prevention and rapid re-housing assistance:  Each re-evaluation of eligibility must establish that the program participant has an annual income that does not exceed 30 percent of median family income for the area, as determined by HUD. (24 CFR § 576.401(b)(1)(i)).  Rapid Re-Housing program participants must be re-evaluated not less than once annually and Homelessness Prevention program participants must be re-evaluated not less than once every three months. If the re-evaluation shows that the program participant is no longer eligible for ESG, assistance must be stopped at that time.  

If income over AMI is discovered outside of the re-evaluation process for homelessness prevention and rapid re-housing assistance:  HUD does not require recipients/subrecipients to conduct a re-evaluation outside of the regular re-evaluation process if information becomes available to indicate that a household has (or may have) increased income or a change in household circumstances that affect eligibility for the program.  However, the recipient/subrecipient has discretion to institute its own standards and MAY require each program participant receiving Rapid Re-Housing or Homelessness Prevention assistance to provide information about changes in income or other circumstances (e.g., household composition) that affect the program participant’s need for assistance. When a program participant notifies a recipient/subrecipient of a relevant change because the notification is REQUIRED, the recipient/subrecipient MUST re-evaluate the program participant’s eligibility and the amount and types of assistance the program participant needs (see 24 CFR § 576.401(b)(2)). If the re-evaluation shows that the program participant is no longer eligible for ESG, assistance must be stopped at that time.  

If the recipient/subrecipient has NOT required such a notification, simply receiving information about a change in a program participant's situation outside of the re-evaluation process (e.g., through case management or credit repair activities) has no immediate effect on the program participant’s eligibility for ESG, and ESG assistance can continue until the next re-evaluation. At that time, the re-evaluation will determine whether the program participant continues to be eligible for ESG assistance.

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For those program participants who, at the last recertification before HPRP ends, are not going to be able to remain stably housed without assistance, ESG funds may be used to help them after HPRP funds are no longer available. If that is the case, they must meet one of the seven criteria listed in category one of the at-risk of homelessness definition at 24 CFR 576.2. A complete eligibility/intake assessment must be conducted and includes having...
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For those program participants who, at the last recertification before HPRP ends, are not going to be able to remain stably housed without assistance, ESG funds may be used to help them after HPRP funds are no longer available.

If that is the case, they must meet one of the seven criteria listed in category one of the at-risk of homelessness definition at 24 CFR 576.2. A complete eligibility/intake assessment must be conducted and includes having an income below 30 percent of median family income for the area, as determined by HUD, and lacking the resources and support networks to prevent them from going into an emergency shelter or one of the places listed in paragraph (1) of the Homeless definition at 24 CFR 576.2. If they are eligible for ESG, you will need to exit them out of HPRP (including exiting them out in HMIS). Since they are already in housing, they would not qualify for rapid re-housing assistance, it would be categorized as homelessness prevention.

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The Equal Access Rule defines family as follows: Family includes, but is not limited to, regardless of marital status, actual or perceived sexual orientation, or gender identity, the following: A single person, who may be an elderly person, displaced person, disabled person, near-elderly person, or any other single person; or, A group of persons residing together, and such group includes, but is not limited to: A family with or without children...
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The Equal Access Rule defines family as follows:

Family includes, but is not limited to, regardless of marital status, actual or perceived sexual orientation, or gender identity, the following:

1. A single person, who may be an elderly person, displaced person, disabled person, near-elderly person, or any other single person; or,
2. A group of persons residing together, and such group includes, but is not limited to:
   1. A family with or without children (a child who is temporarily away from the home because of placement in foster care is considered a member of the family);
   2. An elderly family;
   3. A near-elderly family;
   4. A disabled family;
   5. A displaced family; and,
   6. The remaining member of a tenant family.

In general, this definition of “family” applies to both the ESG and CoC Program rules. However, the McKinney-Vento Act, as amended by the HEARTH Act, distinguishes individuals from families. Therefore, paragraph (1) of the definition of family under the Equal Access Rule is considered an individual under the CoC and ESG programs and the definition of family for these programs is defined as follows:

Family includes, but is not limited to, regardless of marital status, actual or perceived sexual orientation, or gender identity, any group of persons presenting for assistance together with or without children and irrespective of age, relationship, or whether or not a member of the household has a disability. A child who is temporarily away from the home because of placement in foster care is considered a member of the family.

What this means is that any group of people that present together for assistance and identify themselves as a family, regardless of age or relationship or other factors, are considered to be a family and must be served together as such. Further, a recipient or subrecipient receiving funds under the ESG or CoC Programs cannot discriminate against a group of people presenting as a family based on the composition of the family (e.g., adults and children or just adults), the age of any member’s family, the disability status of any members of the family, marital status, actual or perceived sexual orientation, or gender identity.

Here are two examples of how this might apply:

1. An emergency shelter, transitional housing project, or permanent housing project that serves households with children. While it is acceptable for a shelter or housing program to limit assistance to households with children, it may not limit assistance to only women with children. Such a shelter must also serve the following family types, should they present, in order to be in compliance with the Equal Access rule:
   • Single male head of household with minor child(ren); and
   • Any household made up of two or more adults, regardless of sexual orientation, marital status, or gender identity, presenting with minor child(ren).
      

   In this example, the emergency shelter or housing program would not be required to serve families composed of only adult members and could deny access to these types of families provided that all adult-only families are treated equally, regardless of sexual orientation, marital status, or gender identity.

2. A permanent supportive housing project under the CoC Program rule that serves chronically homeless families. A permanent supportive housing program that serves families must serve all types of families and cannot discriminate against any family based on marital status, actual or perceived sexual orientation of the family members, or gender identities of the family members. Therefore, if two adults present together as a family, the recipient or subrecipient must serve the two adults as a family and may not require proof of marriage and may not limit assistance to couples in a heterosexual relationship.

This policy applies to any recipient and subrecipient of funding under ESG or the CoC Program, including faith-based organizations that accept funds through these programs.

All recipients and subrecipients are encouraged to review their current policies and procedures to ensure that they are compliant with this rule.

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The recipient must document the eligibility of all program participants upon their intake to the program. In general, §576.500 of the ESG Program interim rule requires recipients to maintain and follow written intake procedures to determine compliance with the homeless definition found in §576.2. These procedures must require documentation at intake, of the evidence relied upon to establish and verify homeless status. The procedures must e...
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The recipient must document the eligibility of all program participants upon their intake to the program. In general, §576.500 of the ESG Program interim rule requires recipients to maintain and follow written intake procedures to determine compliance with the homeless definition found in §576.2. These procedures must require documentation at intake, of the evidence relied upon to establish and verify homeless status. The procedures must establish the following order of priority for obtaining evidence:

1. Third-party documentation, including written and source documentation, and HMIS records;
2. Intake worker observations; 
3. Certification from persons seeking assistance.

For information about documenting eligibility in emergency shelters, see the FAQ: What is acceptable documentation of eligibility for homeless individuals and families at a nightly turnout emergency shelter, and when is it required?

For more information about recordkeeping requirements for the homeless definition, please view the Determining Homeless and At-Risk Status, Income and Disability Webinar.

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The recordkeeping requirements found in §576.500 require recipients to maintain and follow written intake procedures to determine whether potential program participants meet the homeless definition found in §576.2. These procedures must require documentation at intake of the evidence relied upon to establish and verify homeless status.  Therefore, recipients and subrecipients are required to document eligibility at program entry, even for ...
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The recordkeeping requirements found in §576.500 require recipients to maintain and follow written intake procedures to determine whether potential program participants meet the homeless definition found in §576.2. These procedures must require documentation at intake of the evidence relied upon to establish and verify homeless status. 

Therefore, recipients and subrecipients are required to document eligibility at program entry, even for emergency shelters. However, HUD recognizes that third-party documentation at the emergency shelter level is not feasible in most cases. For shelters where program participants may stay only one night and must leave in the morning, documentation must be obtained each night. If program participants may stay more than one night, then documentation must be obtained on the first night the household stays in the shelter.

Recipients and subrecipients operating emergency shelters can document homeless status through a certification by the individual or head of household as the primary method of establishing homeless eligibility. In these instances, one method of meeting this standard would be to require households to complete a sign-in sheet, with a statement at the top informing the individual or head of household that by signing, they certify that they are homeless. Note: Under no circumstances must the lack of third-party documentation prevent an individual or family from being immediately admitted to emergency shelter, receiving street outreach services, or being immediately admitted to shelter or receiving services provided by a victim service provider.

Note that this is a different standard for recordkeeping than is required for all other types of assistance. For all other types of assistance funded under the ESG Program, the interim rule establishes the following order of priority for obtaining evidence:

1. Third-party documentation, including written and source documentation, and HMIS records; 
2. Intake worker observations;
3. Certification from persons seeking assistance.

Note: Emergency shelter providers do need to enter each individual or family seeking emergency shelter into HMIS. However, the intake process should be able to be done fairly quickly. HUD does not require the same level of intake assessment at entry to an emergency shelter – especially a “nightly turnout” shelter – as for a Rapid Re-housing or Homelessness Prevention program. HUD only requires the uniform data elements at entry. If emergency shelters want to complete a vulnerability index or similar assessment to help understand and address each individual or family’s needs, this does not need to be done at intake and could be conducted at a later time.

For more information about recordkeeping requirements for the homeless definition, please view the Determining Homeless and At-Risk Status, Income and Disability Webinar.

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Documentation of each program participant's qualification as homeless or at risk of homelessness and other program participant records must be retained in accordance with the requirements at 24 CFR part 576.500(y). Recipients/subrecipients may store files electronically, but must be able to produce records in hard copy upon request, or allow them to be viewed as part of an on-site or remote monitoring or audits conducted by designated federal age...
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Documentation of each program participant's qualification as homeless or at risk of homelessness and other program participant records must be retained in accordance with the requirements at 24 CFR part 576.500(y). Recipients/subrecipients may store files electronically, but must be able to produce records in hard copy upon request, or allow them to be viewed as part of an on-site or remote monitoring or audits conducted by designated federal agency staff or by the HUD Office of Inspector General. Additionally, if the recipient/subrecipient uses an electronic system, it must maintain an adequate back-up system for the files, and must ensure that privacy protections are established and followed that adhere to other federal privacy regulations, such as HIPAA (Health Insurance Portability & Accountability Act).

The OMB OmniCircular, at 2 CFR part 200.335, encourages the use of electronic recordkeeping whenever practicable.

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Yes, under the ESG program, you are required to keep a record of all clients that are screened and classified as ineligible. The ESG recordkeeping and reporting requirements state that for each individual and family determined ineligible to receive ESG assistance, the record must include documentation of the reason for that determination. (See 24 CFR § 576.500(d)). With regard to entering data into an HMIS, the ESG regulation does not require th...
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Yes, under the ESG program, you are required to keep a record of all clients that are screened and classified as ineligible. The ESG recordkeeping and reporting requirements state that for each individual and family determined ineligible to receive ESG assistance, the record must include documentation of the reason for that determination. (See 24 CFR § 576.500(d)).

With regard to entering data into an HMIS, the ESG regulation does not require that data about individuals or families determined to be ineligible be entered into an HMIS. (See 24 CFR § 576.400(f)). However, recipients/subrecipients MAY use an HMIS to retain this information if they wish to do so. In addition, HUD provides recipients with considerable discretion in designing their local program requirements. So a recipient may require its subrecipients to report on these individuals or families in an HMIS, and this should be tracked under either outreach/engagement or case management. Note that if individuals or families who are determined ineligible are reported in an HMIS, it is important that they NOT be included when reporting to HUD on persons assisted with ESG funds.

Subrecipients should be sure to check with their local recipient to find out about any local policies governing recordkeeping and reporting requirements.

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Recipients and subrecipients should review the ESG regulation at §576.500 for the minimum acceptable evidence required to document each category of the homeless definition. The most relevant sections are § 576.500(b) through (f), which provide a detailed checklist. For purposes of determining and documenting homelessness, HUD allows various types of documentation in the following order of priority: third-party documentation first, intake worker...
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Recipients and subrecipients should review the ESG regulation at §576.500 for the minimum acceptable evidence required to document each category of the homeless definition. The most relevant sections are § 576.500(b) through (f), which provide a detailed checklist. For purposes of determining and documenting homelessness, HUD allows various types of documentation in the following order of priority: third-party documentation first, intake worker observations second, and certification from the person seeking assistance third.

However, minimum acceptable types of documentation vary depending on the particular housing status and circumstance being documented. In particular, while third party documentation should be obtained whenever possible, lack of third-party documentation must not prevent an individual or family from being immediately admitted to emergency shelter, receiving street outreach services, or being immediately admitted to shelter or receiving services provided by a victim service provider (24 CFR § 576.500(b)).

Note that HUD is working to prepare guidance documents to assist recipients and subrecipients with these and other issues.

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Yes.

Funding Allocation

No. The FY2011 funds must be accounted for separately from the FY2012 funds. Also, HUD must sign the FY11 grant agreement amendment for the second allocation. However, recipients may combine the second allocation of FY2011 funds with FY2012 funds for the purposes of a subrecipient competition, as long as the funds are accounted for separately AND recipients track and meet all of the obligation deadlines separately (60 days for States and 180 days...
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No. The FY2011 funds must be accounted for separately from the FY2012 funds. Also, HUD must sign the FY11 grant agreement amendment for the second allocation. However, recipients may combine the second allocation of FY2011 funds with FY2012 funds for the purposes of a subrecipient competition, as long as the funds are accounted for separately AND recipients track and meet all of the obligation deadlines separately (60 days for States and 180 days for local jurisdictions and territories).

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Expenditure date for FY 2011 first allocation ESG funds:  Funds provided under the first allocation must be expended within 24 months after the date HUD signed the original FY 2011 grant agreement. Recipients have the option of reprogramming funds from the first allocation of FY 2011 grant funds for eligible activities under the Emergency Solutions Grants Program. These funds also must be expended within 24 months after the date HUD signed t...
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Expenditure date for FY 2011 first allocation ESG funds: 

Funds provided under the first allocation must be expended within 24 months after the date HUD signed the original FY 2011 grant agreement. Recipients have the option of reprogramming funds from the first allocation of FY 2011 grant funds for eligible activities under the Emergency Solutions Grants Program. These funds also must be expended within 24 months after the date HUD signed the original FY 2011 grant agreement.

Expenditure date for FY 2011 second allocation ESG funds:

Funds provided under the second allocation must be expended within 24 months after the date HUD signed the amendment to the recipient’s FY 2011 grant agreement.

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Funds from the FY 2011 first allocation are subject to the Emergency Shelter Grants program requirements, which were in effect at the time the awards were made. Any funds from this allocation that recipients or subrecipients continue to expend as originally planned must follow the Emergency Shelter Grants program rule. Any funds reprogrammed from the first allocation after January 4, 2012 must follow the Emergency Solutions Grants program rule. T...
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Funds from the FY 2011 first allocation are subject to the Emergency Shelter Grants program requirements, which were in effect at the time the awards were made. Any funds from this allocation that recipients or subrecipients continue to expend as originally planned must follow the Emergency Shelter Grants program rule. Any funds reprogrammed from the first allocation after January 4, 2012 must follow the Emergency Solutions Grants program rule. The Emergency Solutions Grants Program requirements will govern allocations in FY 2012 and beyond. The Emergency Shelter Grants Program requirements will remain effective for the FY 2011 first allocation and allocations for FY 2010 and earlier.

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Congress allocates funding to ESG on an annual basis. HUD will set aside for allocation to the territories up to 0.2 percent, but not less than 0.1 percent, of the total amount of each appropriation in any fiscal year. The remainder will be allocated to States, metropolitan cities, and urban counties. The percentage allocated to States, metropolitan cities, and urban counties will be equal to the percentage of the total amount available under the...
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Congress allocates funding to ESG on an annual basis. HUD will set aside for allocation to the territories up to 0.2 percent, but not less than 0.1 percent, of the total amount of each appropriation in any fiscal year. The remainder will be allocated to States, metropolitan cities, and urban counties. The percentage allocated to States, metropolitan cities, and urban counties will be equal to the percentage of the total amount available under the Community Development Block Grant (CDBG) for the prior fiscal year. If an allocation to a metropolitan city or urban county would be less than 0.05 percent of the total fiscal year appropriation for ESG, the amount is added to the allocation of the State in which the city or county is located.

There has been no change in the allocation process from the Emergency Shelter Grants program that is now being used for the Emergency Solutions Grants program.

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Yes, such a unit would have to meet the minimum habitability requirements. ESG funds cannot be used to help a program participant remain in or move into housing that does not meet the minimum habitability standards provided in 24 CFR § 576.403(c).

Habitability Standards

Yes, habitability standards (24 CFR § 576.403(c)) apply any time ESG funds are used to help a program participant remain in or move into housing under the Rapid Re-housing or Homelessness Prevention components. This would include providing only rental arrears assistance, only security deposit, only legal assistance, only credit repair, etc.  In cases where the program participant will be moving to a new unit, the habitability requirement ap...
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Yes, habitability standards (24 CFR § 576.403(c)) apply any time ESG funds are used to help a program participant remain in or move into housing under the Rapid Re-housing or Homelessness Prevention components. This would include providing only rental arrears assistance, only security deposit, only legal assistance, only credit repair, etc. 

In cases where the program participant will be moving to a new unit, the habitability requirement applies to the new unit the program participant will move to, not to the unit the household is leaving.

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The CoC is responsible for designating the HMIS and the HMIS Lead Agency for the geographic area that the CoC covers. HUD encourages CoCs and ESG recipients to work together with the HMIS Lead to coordinate HMIS policies and procedures and ensure the HMIS meets the needs of their respective programs; however, only CoCs have the authority to designate the HMIS and the HMIS Lead Agency.  ESG recipients and subrecipients must use the HMIS in th...
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The CoC is responsible for designating the HMIS and the HMIS Lead Agency for the geographic area that the CoC covers. HUD encourages CoCs and ESG recipients to work together with the HMIS Lead to coordinate HMIS policies and procedures and ensure the HMIS meets the needs of their respective programs; however, only CoCs have the authority to designate the HMIS and the HMIS Lead Agency. 

ESG recipients and subrecipients must use the HMIS in the CoC in which the ESG activities are located. The ESG Interim Rule does not permit an ESG recipient to mandate the use of an alternative HMIS than the one already designated by the CoC.

 

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For cash match, “provided” means when the funds are expended (or when the allowable cost is incurred). For in-kind match, it is the date the service (or other in-kind match source) is actually provided to the program or project. Remember that ESG matching funds must be expended within the same expenditure deadline that applies to the ESG funds being matched (i.e. the 24-month deadline). Non-cash contributions must be made within the...
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For cash match, “provided” means when the funds are expended (or when the allowable cost is incurred). For in-kind match, it is the date the service (or other in-kind match source) is actually provided to the program or project. Remember that ESG matching funds must be expended within the same expenditure deadline that applies to the ESG funds being matched (i.e. the 24-month deadline). Non-cash contributions must be made within the expenditure deadline.

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Community Services Block Grant (CSBG) funds may be used to meet the match requirements for HUD's McKinney-Vento programs, including the Emergency Solutions Grants Program, as long as HUD's Appropriations Act language includes a provision authorizing recipients under HUD's McKinney-Vento Homeless Assistance Act programs to use other federal funds as match, and as long as the CSBG Act does not explicitly prohibit it. This provision was included for...
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Community Services Block Grant (CSBG) funds may be used to meet the match requirements for HUD's McKinney-Vento programs, including the Emergency Solutions Grants Program, as long as HUD's Appropriations Act language includes a provision authorizing recipients under HUD's McKinney-Vento Homeless Assistance Act programs to use other federal funds as match, and as long as the CSBG Act does not explicitly prohibit it. This provision was included for FY 2011 through FY 2018 so CSBG funds from those fiscal year allocations may be used to match ESG funds. However, if Congress does not include this provision in future Appropriations Act language, then using any federal funds as match for ESG funds will not be allowable.

It is important to note that any CSBG funds used for matching the ESG program must be used for the purposes of, and in accordance with the requirements of, both CSBG and the ESG program. Please see the information that the U.S. Department of Health and Human Services issued about using CSBG as match for the ESG Program, CoC Program, and other HUD programs.

View the CSBG IM #135 Federal Matching Requirements HUD McKinney-Vento resource.

View the CSBG Dear Colleague Letter Innovation in Response to Homelessness resource.

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If the recipient is a State:  The recipient must share its funds for administrative costs with subrecipients that are units of general purpose local government.  The recipient may share its funds for administrative costs with subrecipients that are private nonprofit organizations.  If the recipient is a territory, metropolitan city, or urban county, the recipient may share its funds for administrative costs with its subrecipient...
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If the recipient is a State: 

• The recipient must share its funds for administrative costs with subrecipients that are units of general purpose local government. 


• The recipient may share its funds for administrative costs with subrecipients that are private nonprofit organizations. 

If the recipient is a territory, metropolitan city, or urban county, the recipient may share its funds for administrative costs with its subrecipients. (24 CFR § 576.108(b))

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It applies to metropolitan cities, urban counties, and territories - the Interim Rule states that each recipient that is not a State must provide for the participation of at least one homeless or formerly homeless person on the board of directors or other equivalent policy making entity of the recipient. (See 24 CFR § 576.405(a)). If a metropolitan city, urban county, or territory is unable to provide for the participation of at least one homele...
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It applies to metropolitan cities, urban counties, and territories - the Interim Rule states that each recipient that is not a State must provide for the participation of at least one homeless or formerly homeless person on the board of directors or other equivalent policy making entity of the recipient. (See 24 CFR § 576.405(a)). If a metropolitan city, urban county, or territory is unable to provide for the participation of at least one homeless or formerly homeless person on the board of directors or other equivalent policy making entity of the recipient, the recipient may develop and implement a plan (as part of the Annual Action Plan) to consult with homeless or formerly homeless individuals in considering and making policies and decisions regarding any ESG-funded facilities, services, or other assistance. Note that this requirement is on the recipient; therefore, recipients may not pass this requirement to their subrecipients as their plan to meet the requirement. However, recipients have the discretion to ALSO require subrecipients to provide for the participation of homeless or formerly homeless person(s) on their board or policy making entity.

This requirement does NOT apply to a recipient that is a State, or to subrecipients. State recipients may also require subrecipients to provide for the participation of homeless or formerly homeless person(s) on their board or policy making entity. (See 24 CFR § 576.405(b)).

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ESG funds may be used to provide security deposits to help veterans move into units receiving HUD-VASH rental assistance, as long as the security deposit is not being paid for with another source of funds. ESG may not be used to provide rental assistance during the same period of time that HUD-VASH is providing rental assistance for the same participant. (See 24 CFR § 576.106).

Program Requirements - General

Yes, as long as the recipient’s residents benefit from that use, as described below. Because ESG allocations are based on recipients’ relative needs, each recipient must use its funds to benefit its own residents. Accordingly, any use of funds outside the jurisdiction must benefit the recipient’s residents. Here are some examples:  The recipient is an urban county and determines that it can serve its residents by funding a shelter or ...
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Yes, as long as the recipient’s residents benefit from that use, as described below.

Because ESG allocations are based on recipients’ relative needs, each recipient must use its funds to benefit its own residents. Accordingly, any use of funds outside the jurisdiction must benefit the recipient’s residents. Here are some examples: 

1. The recipient is an urban county and determines that it can serve its residents by funding a shelter or service provider located in the middle of the county but outside the urban county’s boundaries. 


2. The recipient uses funds outside its boundaries for a jointly funded activity (such as a centralized assessment system) that serves the whole Continuum of Care area and benefits the recipient’s residents in reasonable proportion to the recipient’s share of the activity’s funding.    


3. A resident of the recipient’s jurisdiction is eligible for rapid re-housing assistance but wants to live in an area outside the recipient’s boundaries and the recipient does not require that all program participants live within a particular area for the period in which the rental assistance is provided (pursuant to 24 CFR § 576.106). 

In circumstances like these, where the funds actually benefit the recipient’s residents, the recipient may use ESG funds outside its boundaries. However, the recipient should also keep in mind:

1. The recipient’s action plan must describe any intention to fund an activity outside the recipient’s boundaries (including the percentage of funds designated for that activity) and explain how that activity addresses the recipient’s priority needs and objectives, as required under 24 CFR § 91.220(d) and (f) for local governments and 24 CFR § 91.320(d) and (f) for states. 


2. If a recipient funds an activity outside the recipient’s boundaries, the recipient must ensure through its subrecipient agreement that the funds will be used to benefit the recipient’s residents.

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For Rapid Re-Housing, an income assessment is not required at initial evaluation. However, at annual re-evaluation, income must be LESS THAN OR EQUAL TO 30% AMI. For Homelessness Prevention assistance, households must have an income BELOW 30% AMI at initial evaluation, and have no other housing options, financial resources, or support networks. At re-evaluation - not less than once every three months - the participant must have an annual income L...
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For Rapid Re-Housing, an income assessment is not required at initial evaluation. However, at annual re-evaluation, income must be LESS THAN OR EQUAL TO 30% AMI.

For Homelessness Prevention assistance, households must have an income BELOW 30% AMI at initial evaluation, and have no other housing options, financial resources, or support networks. At re-evaluation - not less than once every three months - the participant must have an annual income LESS THAN OR EQUAL TO 30% AMI.

The 30% AMI limit does not apply to program participants who are being served under the Emergency Shelter or Street Outreach components.

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According to the ESG regulation 24 CFR § 576.100, the total amount of a recipient’s fiscal year grant that may be used for street outreach and emergency shelter activities combined cannot exceed the greater of: 60 percent of the recipient’s fiscal year grant; or The amount of the Fiscal Year 2010 grant funds committed for homeless assistance activities. This amount includes all homeless assistance activities from FY 2010. Homeless assistanc...
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According to the ESG regulation 24 CFR § 576.100, the total amount of a recipient’s fiscal year grant that may be used for street outreach and emergency shelter activities combined cannot exceed the greater of:

1. 60 percent of the recipient’s fiscal year grant; or
2. The amount of the Fiscal Year 2010 grant funds committed for homeless assistance activities. This amount includes all homeless assistance activities from FY 2010. Homeless assistance includes all activities that recipients would report as homeless assistance activities in the Integrated Disbursement Information System (IDIS) for the Emergency Shelter Grants program (emergency shelter renovation, major rehabilitation, conversion, essential services, maintenance, operation, etc.). It excludes ESG funds expended on administrative activities and homelessness prevention activities.

For additional guidance, please review the Notice of the FY 2011 Substantial Amendment Process and Other Related Information for Recipients of ESG Program Funds. This Notice advises the public of the award amounts and spending restrictions on the second allocation of FY 2011 Emergency Solutions Grants funding.

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The requirements for matching ESG funds are described in section 576.201 of the ESG Interim Rule, and the requirements for documenting matching contributions are described in section 576.500(o). In general, federal (other than ESG), state, local, or private funds may be used to satisfy the requirement that the recipient provide matching contributions to ESG, so long as the following conditions are met: The matching funds are contributed to the E...
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The requirements for matching ESG funds are described in section 576.201 of the ESG Interim Rule, and the requirements for documenting matching contributions are described in section 576.500(o).

In general, federal (other than ESG), state, local, or private funds may be used to satisfy the requirement that the recipient provide matching contributions to ESG, so long as the following conditions are met:

1. The matching funds are contributed to the ESG program and expended for the recipient or subrecipient’s allowable ESG costs.* 


2. If the matching funds are from another federal program, there is no specific statutory prohibition on using those funds as match; 


3. The matching funds are used in accordance with all requirements that apply to ESG grant funds, except for the expenditure limits in 24 CFR 576.100. This includes requirements such as documentation requirements, eligibility requirements, and eligible costs. 


4. The matching funds are expended (that is, the allowable cost is incurred) after the date HUD signs the grant agreement for the ESG funds being matched.  


5. The matching funds are expended by the expenditure deadline that applies to the ESG funds being matched;


6. The matching funds have not been and will not be used to match any other Federal program’s funds nor any other ESG grant;


7. The recipient does not use ESG funds to meet the other program's matching requirements; and


8. The recipient keeps records of the source and use of the matching funds, including the particular fiscal year ESG grant for which the matching contribution is counted.

*Note: because the matching funds are contributed to the ESG program and expended for the recipient or subrecipient’s allowable ESG costs, the following are not allowed to be used as match: 

• SNAP benefits (food stamps), because the funds are being used to cover the program participant’s costs;


• Housing Choice Vouchers, because the funds are used to pay the PHA’s obligations under its Housing Assistance Payment contract with the owner; and 


• The tenant’s portion of the rent, because this amount is the tenant’s obligation.

Please also note the following: 

• HUD’s matching requirement applies to the recipient. HUD provides the recipient with the discretion to pass that requirement on to subrecipients. 


• The matching funds are provided based on the total grant amount and do not have to be provided on a component-by-component basis. For example, if a recipient is spending $10,000 on HMIS, they do not need to find $10,000 in data collection funds from another source to use as match. 


• HOME-TBRA funds cannot be used as match because the requirements for rental assistance are significantly different between the two programs. In particular, under the HOME TBRA program (24 CFR parts 92.209 and 92.253), a PJ and its subrecipient(s) may not require a program participant to accept any services (a PJ and its subrecipient(s) may offer services, but cannot require them). In contrast, when providing ESG homelessness prevention or rapid re-housing assistance to a program participant, the recipient or subrecipient must require the program participant to meet with a case manager not less than once per month to assist the program participant in ensuring long-term housing stability and develop a plan to assist the program participant to retain permanent housing after the ESG assistance ends (24 CFR 576.401(e)). Because of these differences in the two programs, HOME TBRA funds may not be used as Match for the ESG funds.


• SHP funds generally cannot be used as match, because very few activity costs are allowable under both SHP and ESG. However, in some cases, such as where SHP funds are used for HMIS or street outreach costs that are allowable under ESG, SHP funds can be counted as match in accordance with conditions 1-8 above. Please note, however, that HMIS costs are only eligible to be used as match under ESG if they are eligible under section 576.107 and allocable to the ESG program, whether charged as direct costs or indirect costs. If the SHP HMIS funds are being used to pay for SHP projects’ data entry, those data entry costs are not allocable to the ESG program and the funds used cannot be counted as match.

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It may help to call HUDVET, a toll free hotline that provides information to veterans seeking answers to housing questions. The HUDVET National Hotline is 1-800-998-9999. Additionally, the HUDVET website offers general veteran updates, as well as contact information for veteran service providers and federal, state, and city governments.  For additional resources, visit the Resources for Homeless Veterans page on the OneCPD Resource Exchange....
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It may help to call HUDVET, a toll free hotline that provides information to veterans seeking answers to housing questions. The HUDVET National Hotline is 1-800-998-9999. Additionally, the HUDVET website offers general veteran updates, as well as contact information for veteran service providers and federal, state, and city governments. 

For additional resources, visit the Resources for Homeless Veterans page on the OneCPD Resource Exchange. There you will find more information about HUD programs for Veterans, as well as links to other federal resources.

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HUD recognizes that planning processes vary from community to community. The consultation requirements were developed broadly, in order to accommodate this variety. HUD expects that ESG recipients and CoC leadership will work together to determine the most effective process for their community.

Program Requirements - General

HUD requires that providers start entering data into an HMIS as soon as they begin serving people using funds from the second allocation. If a provider does not receive any funding from the second allocation, they are required to start entering data on people served using FY2012 funds. However, recipients can require providers to enter sooner if they choose.

Program Requirements - General

Use of FY 2012 ESG grant funds is subject to the Interim Rule.   For ESG recipients whose plans have been submitted and already approved. The recipient will need to submit a substantial amendment to the FY 2012 Action Plan that meets all of the new Con Plan requirements highlighted and explained in the Substantial Amendment Notice, including all requirements that apply to emergency shelter and street outreach activities. The recipient must s...
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Use of FY 2012 ESG grant funds is subject to the Interim Rule.  

For ESG recipients whose plans have been submitted and already approved. The recipient will need to submit a substantial amendment to the FY 2012 Action Plan that meets all of the new Con Plan requirements highlighted and explained in the Substantial Amendment Notice, including all requirements that apply to emergency shelter and street outreach activities. The recipient must submit new ESG certifications with its substantial amendment. Updated certifications are on the OneCPD Resource Exchange. 

For ESG recipients whose plans were submitted and not yet approved. With respect to FY 2012 and future action plans, the new action plan and certification requirements under 24 CFR part 91, as amended by the Interim Rule, apply to the contents of any plan submitted after January 4, 2012. Please make sure that the ESG portions of plans meet the new ESG-specific requirements under 24 CFR part 91, as amended by the Interim Rule and explained in the Substantial Amendment Notice. 

For ESG recipients which have not yet submitted their plans. Recipients must submit an action plan that meets all of the new requirements.  

For jurisdictions which do not receive ESG funds. With respect to FY 2012 and future action plans, the new action plan requirements under 24 CFR part 91, as amended by the Interim Rule, apply to the contents of any plan submitted after January 4, 2012.

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The Emergency Solutions Grants (ESG) program is in effect as of January 4, 2012, for the second allocation of FY 2011 funds and beyond. ESG requirements also apply to any FY 2011 first allocation funds that are reprogrammed to new ESG activities through the Substantial Amendment to the FY 2011 grant. The Emergency Shelter Grants program will be phased out as recipients expend all funds from the first allocation of FY 2011 and earlier.

Program Requirements - General

The maximum length of time a program participant may receive rental assistance through ESG is 24 months during any 3-year period. Short-term rental assistance is for up to 3 months of rent. Medium-term rental assistance is for more than 3 months, but not exceeding 24 months. Payment of rental arrears consists of a one-time payment for up to 6 months of rent in arrears, including any late fees on those arrears. The limit of up to 24 months of paym...
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The maximum length of time a program participant may receive rental assistance through ESG is 24 months during any 3-year period. Short-term rental assistance is for up to 3 months of rent. Medium-term rental assistance is for more than 3 months, but not exceeding 24 months. Payment of rental arrears consists of a one-time payment for up to 6 months of rent in arrears, including any late fees on those arrears. The limit of up to 24 months of payments must include the arrears payments. For example, if a participant receives assistance for 6 months of rental arrears payments, the maximum amount of monthly rental assistance they may receive is 18 months.

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View System Performance Measure FAQs on the HUD Exchange. The FAQs include answers to general questions as well as questions about specific measures and Homelessness Data Exchange (HDX) submission.

Program Requirements - General

ESG is a formula grant program, which means HUD allocates money to States, urban counties, metropolitan cities, and territories (the recipients), who then usually further provide that funding to non-profit organizations in their areas (subrecipients) to run shelters and provide assistance to persons who are homeless or at risk of becoming homeless.  The best place to start is locally, with your city, county, or state, since they are the reci...
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ESG is a formula grant program, which means HUD allocates money to States, urban counties, metropolitan cities, and territories (the recipients), who then usually further provide that funding to non-profit organizations in their areas (subrecipients) to run shelters and provide assistance to persons who are homeless or at risk of becoming homeless. 

The best place to start is locally, with your city, county, or state, since they are the recipients of funds and they operate programs in your area. They will able to provide you with information on their application process and procedures. A list of ESG Recipients can be found on the HUD Exchange.

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Yes. In order to use funds as match for ESG, the matching contributions must meet all requirements that apply to the ESG funds provided by HUD (see 24 CFR 576.201(c)). Therefore, the program participants served with matching funds must be entered into an HMIS, and must be reported on the CAPER.

CAPER

No. If a provider meets the definition of “victim service provider” as defined at 24 CFR 576.3, then that provider is prohibited from entering any data into the Continuum of Care’s (CoC) local HMIS. However, victim service providers must collect and enter program participant-level data into a comparable database for all of the data elements required for the ESG program. Per the 2014 HMIS Data Standards, this includes all Universal Data Elem...
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No. If a provider meets the definition of “victim service provider” as defined at 24 CFR 576.3, then that provider is prohibited from entering any data into the Continuum of Care’s (CoC) local HMIS. However, victim service providers must collect and enter program participant-level data into a comparable database for all of the data elements required for the ESG program. Per the 2014 HMIS Data Standards, this includes all Universal Data Elements and the Program Specific Data Elements (see page 85 of the 2014 HMIS Data Standards Data Manual). Comparable databases must meet all requirements of an HMIS, but must be distinct from the CoC’s HMIS. HUD does not provide CoCs with a comparable database, and “victim service providers” are encouraged to work with their local CoC and HMIS Lead Agency to develop and implement a comparable database.

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Yes. Providers must report the “project entry date” for program participants for the RRH project as soon as providers determine that they are eligible to receive services or assistance. It is important to distinguish between the “project entry date” and the “residential move-in date” data elements in their Homeless Management Information System (HMIS): “Project entry date” must occur on or before the “residential move-in date.�...
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Yes. Providers must report the “project entry date” for program participants for the RRH project as soon as providers determine that they are eligible to receive services or assistance. It is important to distinguish between the “project entry date” and the “residential move-in date” data elements in their Homeless Management Information System (HMIS):

• “Project entry date” must occur on or before the “residential move-in date.”
   
• “Residential move-in date” captures the date the program participant actually moves into permanent housing.

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It depends. If a recipient’s ESG RRH project has other funding in the project that is contributed to the same overall program that meets ESG requirements (i.e., those non-ESG funds would be eligible as match), then it is appropriate to set up the Homeless Management Information System (HMIS) RRH project to include persons served by that non-ESG funding source and report those persons served on the CAPER. For example, if the provider has an RRH ...
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It depends. If a recipient’s ESG RRH project has other funding in the project that is contributed to the same overall program that meets ESG requirements (i.e., those non-ESG funds would be eligible as match), then it is appropriate to set up the Homeless Management Information System (HMIS) RRH project to include persons served by that non-ESG funding source and report those persons served on the CAPER. For example, if the provider has an RRH project that meets all ESG requirements and uses ESG to pay for rental assistance and funds from a foundation to pay for case management/support services (eligible as match), all persons would be reported - even those persons not assisted with ESG rental assistance.

However, if the RRH project includes non-ESG funds that are not administered in accordance with ESG requirements (i.e., funds that would not be eligible as match), then persons assisted with only those non-ESG RRH funds must not be included in the HMIS RRH project or reported on the CAPER.

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No, in general. Each RRH project should have its own project set-up in the HMIS to be able to generate required Federal reports. The only exception to this would be if the HMIS has been customized with the functionality to combine funding from multiple Federal programs into one project to generate the required reports. In such cases, the HMIS System Administrator should verify this with the HMIS Vendor/Provider prior to setting up the project in ...
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No, in general. Each RRH project should have its own project set-up in the HMIS to be able to generate required Federal reports.

The only exception to this would be if the HMIS has been customized with the functionality to combine funding from multiple Federal programs into one project to generate the required reports. In such cases, the HMIS System Administrator should verify this with the HMIS Vendor/Provider prior to setting up the project in HMIS.

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Yes. Projects that receive ESG funding from multiple ESG recipients must create separate projects in their HMIS for each funding source (e.g., ESG City-funded RRH and ESG State- funded RRH) to distinguish program participants for reporting purposes. HUD recommends that recipients and subrecipients: Work together to design projects that use funds from one ESG recipient to support 100 percent of the ESG costs for each household; and   Not pro...
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Yes. Projects that receive ESG funding from multiple ESG recipients must create separate projects in their HMIS for each funding source (e.g., ESG City-funded RRH and ESG State- funded RRH) to distinguish program participants for reporting purposes.

HUD recommends that recipients and subrecipients:

1. Work together to design projects that use funds from one ESG recipient to support 100 percent of the ESG costs for each household; and
    
2. Not provide ESG assistance to the same household with two different funding sources, if it can be avoided (e.g., providing 2 months of ESG city-funded rental assistance followed by 3 months of ESG State-funded rental assistance) – but rather fully fund assistance for fewer program participants with one source of ESG funding, and assist other program participants with the second source of ESG funding.

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The “total number of shelter bed-nights available” is the total number of beds in all shelters the recipient funded with ESG that were available to program participants during the reporting period (the recipient’s program year). HUD does not require or expect that individual beds within an emergency shelter will be attributed to a funder; that is, HUD does not expect that an HMIS can distinguish an “ESG bed” from any other bed. The...
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The “total number of shelter bed-nights available” is the total number of beds in all shelters the recipient funded with ESG that were available to program participants during the reporting period (the recipient’s program year). HUD does not require or expect that individual beds within an emergency shelter will be attributed to a funder; that is, HUD does not expect that an HMIS can distinguish an “ESG bed” from any other bed. Therefore, recipients should count all emergency shelter beds within each shelter that the recipient funded with ESG.

For example, if all beds are available year-round in all ESG-funded shelters within the recipient’s jurisdiction, multiply the total number of beds (all beds in all ESG-funded shelters) by 365, the total number of nights that the beds were available during the reporting period. In this example, if there were 3 ESG-funded shelters in the jurisdiction, and two had 25 beds available year-round and one had 100 beds available year-round, then you would multiply 150 beds x 365 nights, which is 54,750 bed-nights available. 

If certain beds are seasonal (e.g., only during the winter months) then the recipient must multiply the total number of seasonal beds by the number of nights each bed was available during the reporting period (e.g. 61 days if the beds were only available during December and January of the reporting period). In this example, let’s say one of the 25-bed shelters was a seasonal shelter, open November 1 through March 30 (151 nights). This shelter offers 3,775 bed-nights (25 x 151). The other two (100 beds and 25 beds) are available year-round, so you would multiply 125 beds x 365 nights, which is 45,625. You would add 3,775 + 45,625 for a total of 49,400 bed-nights available. 

The next row, “total number of bed-nights provided,” is the total number of beds in all shelters the recipient funded with ESG that were filled each night during the reporting period. This information should come from the HMIS.

The “Capacity Utilization” row is auto-populated by IDIS, based on the data entered in the preceding rows.

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The IDIS user who generates the voucher and the IDIS user who approves the voucher cannot be the same person.

IDIS

No. ESG recipients can only set up one activity per activity category per grant year in IDIS beginning with the FY2011 allocation. The activity categories are: Street Outreach, Shelter, Homelessness Prevention, Rapid Re-Housing, HMIS, and Administration. For each activity, (under “Activity Funding”), a recipient must identify the funding amount allocated to each sub-recipient organization. Itemizing funding by subrecipient allows IDIS (and th...
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No. ESG recipients can only set up one activity per activity category per grant year in IDIS beginning with the FY2011 allocation. The activity categories are: Street Outreach, Shelter, Homelessness Prevention, Rapid Re-Housing, HMIS, and Administration. For each activity, (under “Activity Funding”), a recipient must identify the funding amount allocated to each sub-recipient organization. Itemizing funding by subrecipient allows IDIS (and the ESG recipient) to track commitments and draws at the subrecipient level. When drawing funds for that activity, the recipient must indicate the subrecipient for the draw. So, every draw by a recipient will only be associated with one subrecipient. Each draw is therefore associated with a specific subrecipient and a specific activity for a specific program year. The PR91 Report has been updated to show the activities and draws by subrecipient for each year's ESG allocation.

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These three activity categories do not have a secondary activity category.

IDIS

No, performance objectives and performance outcomes are predetermined (and cannot be edited) for ESG activities based on activity category.

IDIS

No, ESG recipients should not allow another organization to access this activity since other organizations should not be drawing ESG funds or entering information in IDIS. Only ESG recipients are allowed to enter information in IDIS and draw funds in the “HESG” program path.

IDIS

No, a single IDIS project represents the entire ESG grant that is received by the recipient. IDIS will not allow a recipient to setup more than one ESG project per Grant Year.

IDIS

In IDIS, ESG has its own program and activity setup path titled “H-ESG” (for “HEARTH-ESG”) that requires fewer entries than for the Emergency Shelter Grants Program. The Emergency Solutions Grants Program is not called “H-ESG”; this acronym only refers to the IDIS path for the Emergency Solutions Grants Program.

IDIS

The issue most likely is due to your IDIS ID not being granted privileges to access the Emergency Solutions Grants Program path, which began in 2011 and is called “HESG” in IDIS (in IDIS the “ESG” path and grants refer to the legacy program, Emergency Shelter Grants Program). You can verify your specific user privileges in IDIS by accessing the PR30 - Security Administrator User Profile List report. Work with your local grantee administra...
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The issue most likely is due to your IDIS ID not being granted privileges to access the Emergency Solutions Grants Program path, which began in 2011 and is called “HESG” in IDIS (in IDIS the “ESG” path and grants refer to the legacy program, Emergency Shelter Grants Program).

You can verify your specific user privileges in IDIS by accessing the PR30 - Security Administrator User Profile List report. Work with your local grantee administrator, identified on the PR30 report, to ensure your privileges in IDIS include the HESG grant path.

Detailed instructions can be found in Using IDIS Online for the Emergency Solutions Grants (ESG) Program.

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The CR-60 Subrecipient Information screen is programmed to generate a list of ESG subrecipients based on those set up on the IDIS funding screens for the specific program year. ESG recipients are no longer able to create or add a new subrecipient directly onto the CR-60 screen. To add a subrecipient to the selection list for the CR-60 screen, the user would need to edit the specific program year activity’s funding to include the subrecipient. D...
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The CR-60 Subrecipient Information screen is programmed to generate a list of ESG subrecipients based on those set up on the IDIS funding screens for the specific program year. ESG recipients are no longer able to create or add a new subrecipient directly onto the CR-60 screen.

To add a subrecipient to the selection list for the CR-60 screen, the user would need to edit the specific program year activity’s funding to include the subrecipient.

Detailed instructions can be found in Using IDIS Online for the Emergency Solutions Grants (ESG) Program.

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For each ESG activity recipients must identify each subrecipient that is being funded on the IDIS Activity Funding screens. For ESG, recipients should select Subordinate when identifying the subrecipient organization. However, there are existing organizations that have been set-up in IDIS that are categorized as CarryOut Org. This categorization cannot be changed, and ESG recipients should use the CarryOut Org designation if the subrecipient is a...
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For each ESG activity recipients must identify each subrecipient that is being funded on the IDIS Activity Funding screens. For ESG, recipients should select Subordinate when identifying the subrecipient organization. However, there are existing organizations that have been set-up in IDIS that are categorized as CarryOut Org. This categorization cannot be changed, and ESG recipients should use the CarryOut Org designation if the subrecipient is already entered in the system this way. It is important to consistently select the same subrecipient organization each year to ensure that the entity is not set up in the system multiple times.

When creating a voucher for ESG in IDIS, first search for the specific IDIS Activity. Then, on the Create Voucher – Page 2 of 4 (Drawdown Amounts), include the appropriate dollar amount for the specific subrecipient and activity in the correct Drawdown Amount textbox. The Create Voucher – Page 2 of 4 (Drawdown Amounts) will show the Funded Amount and Available to Draw amount for each subrecipient as currently funded/drawn in IDIS for each activity.

Detailed instructions can be found in Using IDIS Online for the Emergency Solutions Grants (ESG) Program.

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The required naming convention for ESG Activities is: ESG, the 2-digit Federal Allocation Year followed by a space, followed by the Activity Category as listed in IDIS. For example: “ESG19 Shelter” Only one activity may be set up per component per grant. For example, if a recipient funds all ESG components and admin with their FY 2019 grant, then the only activities that may be set up in IDIS are the following, using this naming convention: ...
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The required naming convention for ESG Activities is: ESG, the 2-digit Federal Allocation Year followed by a space, followed by the Activity Category as listed in IDIS.

For example: “ESG19 Shelter”

Only one activity may be set up per component per grant. For example, if a recipient funds all ESG components and admin with their FY 2019 grant, then the only activities that may be set up in IDIS are the following, using this naming convention:

• ESG19 Street Outreach
• ESG19 Shelter
• ESG19 Rapid Re-housing
• ESG19 Homeless Prevention
• ESG19 Data Collection (HMIS)
• ESG19 Administration

Detailed instructions can be found in Using IDIS Online for the Emergency Solutions Grants (ESG) Program.

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The required naming convention for the ESG Project (only one project is created for each grant) is: ESG, the 2-digit Federal Allocation Year followed by a space, followed by the Recipient Name. For example: “ESG19 Columbus” Detailed instructions can be found in Using IDIS Online for the Emergency Solutions Grants (ESG) Program....
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The required naming convention for the ESG Project (only one project is created for each grant) is: ESG, the 2-digit Federal Allocation Year followed by a space, followed by the Recipient Name.

For example: “ESG19 Columbus”

Detailed instructions can be found in Using IDIS Online for the Emergency Solutions Grants (ESG) Program.

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Recipients can find specific information regarding their organization’s expenditure cap on Emergency Shelter and Street Outreach on the PR91 ESG Financial Summary Report. There is a section of the PR91 that identifies the following by grant year: Amount Committed to Shelter Amount Committed to Street Outreach Total Amount Committed to Shelter and Street Outreach Percent Committed to Shelter and Street Outreach 2010 Funds Committed to Homeless ...
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Recipients can find specific information regarding their organization’s expenditure cap on Emergency Shelter and Street Outreach on the PR91 ESG Financial Summary Report.

There is a section of the PR91 that identifies the following by grant year:

• Amount Committed to Shelter
• Amount Committed to Street Outreach
• Total Amount Committed to Shelter and Street Outreach
• Percent Committed to Shelter and Street Outreach
• 2010 Funds Committed to Homeless Assistance Activities
• Total Drawn for Shelter and Street Outreach
• Percent Drawn for Shelter and Street Outreach

The Total Amount Committed and Drawn for Shelter and Street Outreach cannot exceed the greater of:

1. 60% of the overall grant for the year; or
2. the amount of Fiscal Year 2010 Emergency Shelter Grants Program funds committed for homeless assistance activities.

Detailed instructions can be found in Using IDIS Online for the Emergency Solutions Grants (ESG) Program.

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