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The Emergency
Solutions Grants
Program (ESG):
An Overview

Tom Albanese
Abt Associates
National Conference on Ending
Family & Youth Homelessness
February 9, 2012
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
Overview
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
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
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
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
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
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
Components and
Administration of
ESG
The 5 Components of ESG

1) Street Outreach

2) Emergency Shelter

3) Homelessness Prevention

4) Rapid Re-Housing

5) HMIS

                             Abt Associates | pg 11
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
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
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
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
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
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
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
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
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
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
Program
Requirements
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
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
Building the
Bridge: HPRP vs.
ESG
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
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
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
Substantial
Amendment
Process
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
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
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
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
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
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

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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