2.2 Implementing the HEARTH Act: Preparing for the New Emergency Solutions Grant

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


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


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


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


FY 2011 Funding Allocation

* The FY2011 Appropriation directed that HUD fund the ESGprogram for at least $225 million

Emergency Shelter/Solutions Grants


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.


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


The 5 Components of ESG

1) Street Outreach

2) Emergency Shelter

3) Homelessness Prevention

4) Rapid Re-Housing

5) HMIS


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.


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)


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


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


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


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.


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


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)


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


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


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


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


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


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.


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


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


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!


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.


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


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?


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

http://www.hudhre.info/

2.2 Implementing the HEARTH Act: Preparing for the New Emergency Solutions Grant

Documents

2.2 Implementing the HEARTH Act: Preparing for the New Emergency Solutions Grant