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

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

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

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

Speaker: Tom Albanese

Under the HEARTH Act, homelessness prevention and rapid re-housing are eligible activities for the new Emergency Solutions Grant (ESG). Presenters will review the changes to the ESG program and discuss ways to transition programs from HPRP to ESG funding. Presenters will also discuss strategies for implementing ESG and will explore successful program models. Other resources for funding these programs will be explored in workshop 5.6.

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

    • The EmergencySolutions GrantsProgram (ESG):An OverviewTom AlbaneseAbt AssociatesNational Conference on EndingFamily & Youth HomelessnessFebruary 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, 2011Emergency Solutions Effective:Grants Program January 4, 2012and Comments Due:Consolidated Plan February 3, 2012Amendments Substantial Amendment Notice Published: January 27, 2012 Posted: December 9, 2011HMIS Comments due: February 7, 2012 Abt Associates | pg 4
    • Overview of Homeless DefinitionHomeless 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 DefinitionAt-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 6
    • FY 2011 Funding Allocation Emergency Shelter/Solutions Grants* The FY2011 Appropriation directed that HUD fund the ESGprogram for at least $225 million Abt Associates | pg 7
    • Priorities in Developing the ESGRegulation• 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 andAdministration ofESG
    • The 5 Components of ESG1) Street Outreach2) Emergency Shelter3) Homelessness Prevention4) Rapid Re-Housing5) 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 EmergencyShelter Funding Ceiling• Street outreach and emergency shelter expenditures are capped• Combined street outreach and emergency shelter expenditures from each fiscal years ESG grant cannot exceed the greater of: ― 60% of that fiscal years 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 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 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 ServicesAllowable activities for both Homelessness Prevention and RapidRe-housing components:Financial Assistance* Services• Moving costs • Housing search / placement• Rent application fees • Housing stability case• Security deposit management• Last months 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 periodsupported by another public source. Abt Associates | pg 17
    • Short/Medium-Term Rental AssistanceAllowable activities for both Homelessness Prevention and RapidRe-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 RentalAssistanceStandards 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 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
    • ProgramRequirements
    • 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 theBridge: 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
    • SubstantialAmendmentProcess
    • Substantial Amendment NoticeESG 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 TimelineObligation & 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