The Emergency Solutions Grants Program (ESG) provides an overview of the ESG regulation and requirements for its implementation. Key points include: ESG has 5 components - street outreach, emergency shelter, homelessness prevention, rapid re-housing, and HMIS. It requires coordination with Continuums of Care and consistency with Consolidated Plans. Jurisdictions must submit a substantial amendment to their Consolidated Plan by May 15, 2012 to describe how they will use and implement ESG funds. The amendment requires consultation with community stakeholders and approval by HUD.
Evaluating Philadelphia’s Rapid Re-Housing Impacts on Housing Stability and I...
2.2 Implementing the HEARTH Act: Preparing for the New Emergency Solutions Grant
1. The Emergency
Solutions Grants
Program (ESG):
An Overview
Tom Albanese
Abt Associates
National Conference on Ending
Family & Youth Homelessness
February 9, 2012
2. Topics
• Overview of the ESG Regulation
• Components and Administration of ESG
• Program Requirements
• Building the Bridge: HPRP vs. ESG
• Substantial Amendment Process
Abt Associates | pg 2
4. Status of Regulatory Process
Proposed Interim Final
Posted: Posted:
Definition of Homeless April 20, 2010 November 15,
Comments Due: 2011
June 21, 2010
Posted:
November 15, 2011
Emergency Solutions Effective:
Grants Program January 4, 2012
and Comments Due:
Consolidated Plan February 3, 2012
Amendments Substantial Amendment Notice
Published:
January 27, 2012
Posted:
December 9, 2011
HMIS
Comments due:
February 7, 2012
Abt Associates | pg 4
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 subsequent
residence, resources or support networks
3) Unaccompanied youth or families with children/youth who
meet the homeless definition under another federal statute
and 3 additional criteria
4) Individuals/families fleeing or attempting to flee domestic
violence with no subsequent residence, resources or
support networks
Abt Associates | pg 5
6. Overview of At-Risk Definition
At-Risk of Homelessness definition has 3
categories applicable to:
1) Individuals and Families
2) Unaccompanied Children and Youth
3) Unaccompanied Children and Youth and their Families
Abt Associates | pg 6
7. FY 2011 Funding Allocation
Emergency Shelter/Solutions Grants
* The FY2011 Appropriation directed that HUD fund the ESG
program for at least $225 million
Abt Associates | pg 7
8. Priorities in Developing the ESG
Regulation
• Broaden existing emergency shelter and homelessness
prevention activities.
• Emphasize Rapid Re-Housing.
• Help people quickly regain stability in permanent housing
after experiencing a housing crisis and/or homelessness.
• Enhance alignment of ESG regulations with other HUD
programs – including CDBG, HOME, and Housing Choice
Voucher (HCV) program.
• Support more coordinated and effective data collection,
performance measurement, and program evaluation.
Abt Associates | pg 8
9. HEARTH Focus on Outcomes
CoC: performance measurement will focus on CoC
performance 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 are
homeless)
– 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
Abt Associates | pg 9
11. The 5 Components of ESG
1) Street Outreach
2) Emergency Shelter
3) Homelessness Prevention
4) Rapid Re-Housing
5) HMIS
Abt Associates | pg 11
12. 1. Street Outreach Component
• Serves unsheltered homeless persons
• Essential Services include street outreach
services for:
• Engagement
• Case management
• Emergency health and mental health services
• Transportation
• Services for special populations*
*Special Populations include Homeless Youth, Homeless Persons with
HIV/AIDS, and Homeless Victims of Domestic Violence, Sexual
Violence, and Stalking.
Abt Associates | pg 12
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 13
14. Street Outreach and Emergency
Shelter Funding Ceiling
• Street outreach and emergency shelter
expenditures are capped
• Combined street outreach and emergency
shelter expenditures from each fiscal year's
ESG 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 street
outreach and emergency shelter activities
Abt Associates | pg 14
15. 3. Homelessness Prevention
Component
• 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 or
other permanent housing
• Eligible activities:
• Housing Relocation and Stabilization Services
• Short- and Medium-Term Rental Assistance
Abt Associates | pg 15
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 16
17. Housing Relocation and
Stabilization Services
Allowable activities for both Homelessness Prevention and Rapid
Re-housing components:
Financial Assistance* Services
• Moving costs • Housing search / placement
• Rent application fees • Housing stability case
• Security deposit management
• Last month's rent • Mediation and legal services
• Utility deposit • Credit repair/ budgeting/
• Utility payments money management
*No financial assistance to a household for a purpose and time period
supported by another public source.
Abt Associates | pg 17
18. Short/Medium-Term Rental
Assistance
Allowable activities for both Homelessness Prevention and Rapid
Re-housing components:
Rental Assistance
• 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 of
rent arrears on the tenant’s portion of the rent
• Type: Tenant-based or project-based
Abt Associates | pg 18
19. Short/Medium-Term Rental
Assistance
Standards for Both Homelessness Prevention and
Rapid Re-Housing Components:
• FMR limits
• Rent reasonableness
• Minimum habitability standards
• Rental assistance agreement and lease
• No rental assistance to a household receiving rental
assistance from another public source for same time
period (except a one-time payment of up to 6 months
of arrears)
Abt Associates | pg 19
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 the
Consolidated Plan
– Carrying out environmental review responsibilities
• State recipients must share a reasonable amount of funds
for administrative costs with subrecipients that are units of
general purpose local government
• Staff /overhead costs directly related to one of the
program components are NOT subject to the
administrative cost limit
Abt Associates | pg 20
21. Administrative Activities Amounts
• Up to 7.5% of grant may be used for
administrative costs
• The 7.5% is calculated based on the entire
FY 2011 allocation.
• IDIS will be set to allow draws up to 7.5% of
the entire FY 2011 allocation.
Abt Associates | pg 21
23. Program Requirements
• Required to use centralized/coordinated intake,
implement ESG in coordination with CoC
• Coordinate with Continuums of Care on
allocation of funds and performance
measurements
• Consistency with Consolidated Plan
• Connecting participants with mainstream
resources
• Regularly re-evaluating participant eligibility
Abt Associates | pg 23
24. Program Requirements
• Written standards are required to ensure
consistent program administration
• Dollar-for-dollar match (cash or in-kind)
• HMIS Participation
• Financial reporting in IDIS
• Performance reporting
Abt Associates | pg 24
26. Building the Bridge: HPRP vs. ESG
• Communities will be able to draw upon their
knowledge of and experience with HPRP to
implement the new ESG. A few similarities
between 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 26
27. Building the Bridge: HPRP vs. ESG
• Some of the important differences to note between
the programs include:
• HPRP was a short-term stimulus program targeting individuals
and families hit by the economic downturn, whereas ESG is a
permanent program targeting those who are homeless for a
variety of reasons
• ESG covers some activities not eligible under HPRP, such as
emergency 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 over
other program activities, such as homelessness
prevention.
Abt Associates | pg 27
28. Focus on Rapid Re-Housing
• HUD strongly encourages jurisdictions to target new
funds toward assisting individuals and families living
on the streets or in emergency shelter
– Effective Rapid Re-housing can transition people out of
homelessness quickly and decrease the overall number of
people that are homeless in the community
– Homelessness prevention is difficult to strategically target
and potentially inefficient in reducing homelessness
• Rapid Re-housing should be given highest priority
under ESG to ensure that existing resources –
within and outside the homeless assistance system
– are used as efficiently as possible
Abt Associates | pg 28
30. Substantial Amendment Notice
ESG Notice released on January 23, 2012:
• Clarifies requirements for receiving and limitations on
spending FY11 ESG funds
• Includes requirements and guidance for establishing
expenditure limits on emergency shelter and street
outreach activities
• Provides elements that must be included in substantial
amendment, plus optional sections
• Provides guidance on critical decisions to be made in
the planning process for FY 2012 and future
consolidated planning submissions
Abt Associates | pg 30
31. Substantial Amendment Timeline
• Substantial Amendment Deadline: May 15, 2012
• HUD approves substantial amendment within 45
days (regular process)
• HUD does an amendment to the FY11 grant
agreement.
Only once both parties have signed grant
agreement amendment can the recipient spend
funds!
Abt Associates | pg 31
32. Substantial Amendment Timeline
Obligation & Expenditure Deadlines:
• States:
– 60 days to obligate funds to subrecipients (for 2nd allocation of
funds, this is 60 days from date HUD signed grant agreement
amendment)
– Then, any subrecipients that are local governments have 120
days to obligate funds (to any non-profits or designate the local
gov’t department to administer)
• Metropolitan cities, urban counties, and territories:
– Within 180 days, the recipient must obligate all of the grant
amount, except the amount for its administrative costs.
Abt Associates | pg 32
33. Substantial Amendment
Components
• 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 33
34. Implementation Questions
• What can we (as a community) learn from experience with Emergency Shelter
Grants, 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 34
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 ESG
Interim 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 near
future
Abt Associates | pg 35