The Emergency Solutions Grants Program (ESG): An Overview Tom Albanese Abt Associates National Conference on Ending Family & Youth Homelessness February 9, 2012
Dec 23, 2014
The EmergencySolutions GrantsProgram (ESG):
An Overview
Tom Albanese
Abt Associates
National Conference on EndingFamily & Youth Homelessness
February 9, 2012
Abt Associates | pg 2
Topics
• Overview of the ESG Regulation
• Components and Administration of ESG
• Program Requirements
• Building the Bridge: HPRP vs. ESG
• Substantial Amendment Process
Overview
Abt Associates | pg 4
Status of Regulatory ProcessProposed Interim Final
Definition of Homeless
Posted:
April 20, 2010
Comments Due:
June 21, 2010
Posted:
November 15,
2011
Emergency Solutions
Grants Program
and
Consolidated Plan
Amendments
Posted:
November 15, 2011
Effective:
January 4, 2012
Comments Due:
February 3, 2012
Substantial Amendment Notice
Published:
January 27, 2012
HMIS
Posted:
December 9, 2011
Comments due:
February 7, 2012
Abt Associates | pg 5
Overview of Homeless Definition
Homeless definition has 4 categories:
1) Literally homeless individuals/families
2) Individuals/families who will imminently (within 14 days)lose their primary nighttime residence with no subsequentresidence, resources or support networks
3) Unaccompanied youth or families with children/youth whomeet the homeless definition under another federal statuteand 3 additional criteria
4) Individuals/families fleeing or attempting to flee domesticviolence with no subsequent residence, resources orsupport networks
Abt Associates | pg 6
Overview of At-Risk Definition
At-Risk of Homelessness definition has 3categories applicable to:
1) Individuals and Families
2) Unaccompanied Children and Youth
3) Unaccompanied Children and Youth and their Families
Abt Associates | pg 7
FY 2011 Funding Allocation
* The FY2011 Appropriation directed that HUD fund the ESGprogram for at least $225 million
Emergency Shelter/Solutions Grants
Abt Associates | pg 8
Priorities in Developing the ESGRegulation
• Broaden existing emergency shelter and homelessnessprevention activities.
• Emphasize Rapid Re-Housing.
• Help people quickly regain stability in permanent housingafter experiencing a housing crisis and/or homelessness.
• Enhance alignment of ESG regulations with other HUDprograms – including CDBG, HOME, and Housing ChoiceVoucher (HCV) program.
• Support more coordinated and effective data collection,performance measurement, and program evaluation.
Abt Associates | pg 9
HEARTH Focus on Outcomes
CoC: performance measurement will focus on CoCperformance as a system
ESG: performance will impact CoC performance
– Length of time homeless
– Recidivism (subsequent return to homelessness)
– Access/coverage (thoroughness in reaching persons who arehomeless)
– Overall reduction in number of persons who experience homelessness
– Job and income growth for persons who are homeless
– Reduction in first time homeless
Other accomplishments related to reducing homelessness
Components andAdministration ofESG
Abt Associates | pg 11
The 5 Components of ESG
1) Street Outreach
2) Emergency Shelter
3) Homelessness Prevention
4) Rapid Re-Housing
5) HMIS
Abt Associates | pg 12
1. Street Outreach Component
• Serves unsheltered homeless persons
• Essential Services include street outreachservices for:
• Engagement
• Case management
• Emergency health and mental health services
• Transportation
• Services for special populations*
*Special Populations include Homeless Youth, Homeless Persons withHIV/AIDS, and Homeless Victims of Domestic Violence, SexualViolence, and Stalking.
Abt Associates | pg 13
2. Emergency Shelter Component
• Serves people staying in emergency shelters
• Essential Services include:• Case management
• Child care, education, employment, and life skills services
• Legal services
• Health, mental health, and substance abuse services
• Transportation
• Services for special populations
• Shelter activities include:• Renovation (including major rehab or conversion)
• Operations (e.g., maintenance, utilities, furniture, food)
Abt Associates | pg 14
Street Outreach and EmergencyShelter Funding Ceiling
• Street outreach and emergency shelterexpenditures are capped
• Combined street outreach and emergencyshelter expenditures from each fiscal year'sESG grant cannot exceed the greater of:
― 60% of that fiscal year's total ESG grant award
― The amount of FY 2010 grant funds committed to streetoutreach and emergency shelter activities
Abt Associates | pg 15
3. Homelessness PreventionComponent
• Available to persons:– Below 30% of AMI
– Homeless or at risk of becoming homeless
• Can be used:
• To prevent an individual or family from becoming homeless
• To help an individual or family regain stability in current housing orother permanent housing
• Eligible activities:• Housing Relocation and Stabilization Services
• Short- and Medium-Term Rental Assistance
Abt Associates | pg 16
4. Rapid Re-Housing Component
• Available to those who are literally homeless
• Can be used:
• To help a homeless individual or family move into permanent
housing and achieve housing stability
• Eligible activities:
• Housing Relocation and Stabilization Services
• Short- and Medium-Term Rental Assistance
Abt Associates | pg 17
Housing Relocation andStabilization Services
Financial Assistance* Services
• Moving costs• Rent application fees• Security deposit• Last month's rent• Utility deposit• Utility payments
• Housing search / placement• Housing stability case
management• Mediation and legal services• Credit repair/ budgeting/
money management
Allowable activities for both Homelessness Prevention and RapidRe-housing components:
*No financial assistance to a household for a purpose and time periodsupported by another public source.
Abt Associates | pg 18
Short/Medium-Term RentalAssistance
• Definition:
– Short-Term = up to 3 months
– Medium-Term = 4 to 24 months
• Duration: Up to 24 months of rental assistance during any 3-year period, including one-time payment for up to 6 months ofrent arrears on the tenant’s portion of the rent
• Type: Tenant-based or project-based
Allowable activities for both Homelessness Prevention and RapidRe-housing components:
Rental Assistance
Abt Associates | pg 19
Short/Medium-Term RentalAssistance
Standards for Both Homelessness Prevention andRapid Re-Housing Components:
• FMR limits
• Rent reasonableness
• Minimum habitability standards
• Rental assistance agreement and lease
• No rental assistance to a household receiving rentalassistance from another public source for same timeperiod (except a one-time payment of up to 6 monthsof arrears)
Abt Associates | pg 20
Administrative Activities
• Eligible Administrative costs include:– Providing management, oversight, and coordination
– Monitoring programs and evaluating performance
– Training on ESG requirements
– Preparing ESG & homelessness-related sections of theConsolidated Plan
– Carrying out environmental review responsibilities
• State recipients must share a reasonable amount of fundsfor administrative costs with subrecipients that are units ofgeneral purpose local government
• Staff /overhead costs directly related to one of theprogram components are NOT subject to theadministrative cost limit
Abt Associates | pg 21
Administrative Activities Amounts
• Up to 7.5% of grant may be used foradministrative costs
• The 7.5% is calculated based on the entireFY 2011 allocation.
• IDIS will be set to allow draws up to 7.5% ofthe entire FY 2011 allocation.
ProgramRequirements
Abt Associates | pg 23
Program Requirements
• Required to use centralized/coordinated intake,implement ESG in coordination with CoC
• Coordinate with Continuums of Care onallocation of funds and performancemeasurements
• Consistency with Consolidated Plan
• Connecting participants with mainstreamresources
• Regularly re-evaluating participant eligibility
Abt Associates | pg 24
Program Requirements
• Written standards are required to ensureconsistent program administration
• Dollar-for-dollar match (cash or in-kind)
• HMIS Participation
• Financial reporting in IDIS
• Performance reporting
Building theBridge: HPRP vs.ESG
Abt Associates | pg 26
Building the Bridge: HPRP vs. ESG
• Communities will be able to draw upon theirknowledge of and experience with HPRP toimplement the new ESG. A few similaritiesbetween the two programs include:
• Promotion of homelessness prevention and rapid re-housing activities
• HPRP partners are already participating in ESG-required HMIS
• Both are bridge programs for the clients• Emphasis on performance• Larger goals of lessening the length of stay in shelters
and reducing recidivism
Abt Associates | pg 27
Building the Bridge: HPRP vs. ESG
• Some of the important differences to note betweenthe programs include:
• HPRP was a short-term stimulus program targeting individualsand families hit by the economic downturn, whereas ESG is apermanent program targeting those who are homeless for avariety of reasons
• ESG covers some activities not eligible under HPRP, such asemergency shelter and street outreach
• ESG uses the new homeless definition• ESG requires greater collaboration with CoCs• HPRP came with a greater level of funding
• ESG comes with a greater push for rapid re-housing overother program activities, such as homelessnessprevention.
Abt Associates | pg 28
Focus on Rapid Re-Housing
• HUD strongly encourages jurisdictions to target newfunds toward assisting individuals and families livingon the streets or in emergency shelter
– Effective Rapid Re-housing can transition people out ofhomelessness quickly and decrease the overall number ofpeople that are homeless in the community
– Homelessness prevention is difficult to strategically targetand potentially inefficient in reducing homelessness
• Rapid Re-housing should be given highest priorityunder ESG to ensure that existing resources –within and outside the homeless assistance system– are used as efficiently as possible
SubstantialAmendmentProcess
Abt Associates | pg 30
Substantial Amendment Notice
ESG Notice released on January 23, 2012:
• Clarifies requirements for receiving and limitations onspending FY11 ESG funds
• Includes requirements and guidance for establishingexpenditure limits on emergency shelter and streetoutreach activities
• Provides elements that must be included in substantialamendment, plus optional sections
• Provides guidance on critical decisions to be made inthe planning process for FY 2012 and futureconsolidated planning submissions
Abt Associates | pg 31
Substantial Amendment Timeline
• Substantial Amendment Deadline: May 15, 2012
• HUD approves substantial amendment within 45days (regular process)
• HUD does an amendment to the FY11 grantagreement.
Only once both parties have signed grantagreement amendment can the recipient spendfunds!
Abt Associates | pg 32
Substantial Amendment Timeline
Obligation & Expenditure Deadlines:
• States:
– 60 days to obligate funds to subrecipients (for 2nd allocation offunds, this is 60 days from date HUD signed grant agreementamendment)
– Then, any subrecipients that are local governments have 120days to obligate funds (to any non-profits or designate the localgov’t department to administer)
• Metropolitan cities, urban counties, and territories:
– Within 180 days, the recipient must obligate all of the grantamount, except the amount for its administrative costs.
Abt Associates | pg 33
Substantial AmendmentComponents
• Substantial amendment must address the following:
– SF-424
– Summary of Consultation Process
– Summary of Citizen Participation Process
– Matching Resources
– Proposed Activities and Overall Budget
– Written Standards for Provision of ESG Assistance
– Process for Making Sub-awards
– Homeless Participation Requirement
– Performance Standards
– Certifications
– Any optional elements
• Appendix B provides a summary/checklist
Abt Associates | pg 34
Implementation Questions
• What can we (as a community) learn from experience with Emergency ShelterGrants, and from HPRP best practices?
• What can we learn from challenges in implementing HPRP?
• What has HPRP taught us about our community’s needs?
• How can ESG address these needs?
• How will we consult and coordinate with CoC(s)?
• How will we ensure satisfactory HMIS participation by ESG subrecipients?
• How will we address unsatisfactory levels of HMIS participation?
Abt Associates | pg 35
Additional Resources
• HUD’s Homelessness Resource Exchange:
www.hudhre.info
– The published ESG Interim Rule with Consolidated Plan changes
– Consolidated Plan Regulation (highlighting changes from the ESGInterim Rule)
– Notice on application requirements FY 2011 ESG Second Allocation
– ESG Helpdesk
– Webinar recordings and slides
– Additional guidance regarding the Consolidated Plan Regulations(user guide, FAQ, etc.) will be posted to HUD’s HRE in the nearfuture