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The Emergency Solutions Grants (ESG) Program: An Introductory Overview

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1 The Emergency Solutions Grants (ESG) Program: An Introductory Overview
Michael Roanhouse Director, Program Coordination and Analysis Division Office of Special Needs Assistance Programs Welcome to the webinar.

2 “OVERVIEW” Webinar Today’s presentation provides high-level overview and introductory information only. You will need more detailed information from the statute, ESG regulation, and other HUD guidance documents to successfully plan and operate your program! Additional information will be available through: Guides and tools on the HUDHRE.info site Today's training is designed to provide an “overview”– and that is exactly what it is. It will not provide details. Instead, it is designed to get you up to speed on the kinds of activities you will be able to undertake and give you the ‘big picture’ of how the program will work. You won’t be able to develop your program based on this webinar. You will need more detailed information from the regulation and other HUD guidance to successfully operate your program! We can tell you in advance that you will be left with lots of questions. Answers will be available through the resources posted on the HRE, and through the upcoming webinars that are listed at the end of this presentation. If you are unable to find information using these resources, please submit your questions to HUD’s Virtual Help Desk.

3 Today’s Presentation will Cover:
Purpose of the ESG program Explanation of interim rulemaking ESG program components and activities Basic ESG program requirements Actions needed to begin implementing ESG Implementation resources (e.g., webinars, tools on the HRE, ESG Virtual Help Desk) Here’s how we will accomplish those objectives. In this webinar, we will: Discuss briefly the priorities that HUD had in mind in developing this regulation, and where things stand in the process of developing and finalizing all of the regulations relevant to implementing your new ESG program. Provide a high-level overview of the program components and eligible activities. Summarize some of the key program requirements. Provide ideas about next steps communities should take to implement their programs. Identify resources that will help you design and implement your programs. 3 3

4 ESG Terminology How will we refer to the “original” and “amended” ESG programs, since they have the same acronym? Original ESG: “Emergency Shelter Grants program” will be spelled out Amended ESG: “Emergency Solutions Grants” program will adopt the acronym “ESG” The Homeless Emergency Assistance and Rapid Transition to Housing Act of 2009 (Hearth Act) amended the McKinney-Vento Homeless Assistance Act. Among other changes, the HEARTH Act revised the Emergency Shelter Grants program and renamed the program the Emergency Solutions Grants program. From this point forward, the initials ESG will stand for the Emergency Solutions Grants program. Whenever we refer to the program as it existed before publication of the revised regulations, we will spell out “Emergency Shelter Grants” program. Unless they are reprogrammed, previously-awarded funds will continue to be governed by the original Emergency Shelter Grants program regulations that were in place at the time those funds were awarded. The Homelessness Resource Exchange (the HRE) will maintain separate information about the original Emergency Shelter and the amended Emergency Solutions Grants programs.

5 Priorities of the Interim ESG Program
To frame the context for implementing the new ESG regulation and fill you in on HUD’s priorities for the program, we will turn this presentation over to [Mark Johnston and/or Ann Oliva?] [NOTE TO HUD: We assume that whoever is speaking will want to craft their own brief introductory remarks. Most of the substantive content to cover is noted on the next couple of slides. This is a place for the speaker to share HUD’s excitement about launching a revised program. Here are a couple of ideas that you might want to mention:] Welcome from HUD; thanks for participating… We are excited to be here, launching the amended ESG program…. The content of the ESG program reflects HUD’s priorities and statutory requirements The structure of the ESG program reflects what has been learned from HPRP. Note that you will see similarities to the HPRP program, but do not assume that something similar will necessarily be the same. There are differences. 5

6 Priorities in Developing the ESG Regulation
Broaden existing emergency shelter and homelessness prevention activities. 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 the Housing Choice Voucher (HCV) program. Alter framework to support more coordinated and effective data collection, performance measurement, and program evaluation. As we developed the ESG regulation, we were focused on achieving several key things: Broaden the activities available to help people who are on the street. Offer more flexible prevention services to avert homelessness. Focus on permanent housing solutions and the supports necessary to achieve stability. Align ESG to the extent possible with other HUD programs such as CDBG, HOME, and HCV as well as other targeted HUD homeless programs such as CoC and RHS, to support coordinated plans and reduce administrative burden. Structure ESG’s components and activities in a way that will streamline reporting to support coordinated and effective reporting and data collection, and allow for performance measurement and program evaluation.

7 Status of Regulatory Process
Proposed Interim Final Definition of Homelessness April 20, 2010 (Published 12/5/2011) Emergency Solutions Grants Program (ESG) (Comments due 2/3/2012) Consolidated Plan Amendments HMIS (Comments due 2/7/2012) [NOTE TO HUD: Please see what you think about the content. The specific dates and “check marks” will need to be adjusted once the status of each reg on the webinar date is known.] To accomplish all this, we are developing four inter-related regulations. Definition of Homelessness and At Risk of Homelessness Emergency Solutions Grants Program (ESG) Consolidated Plan HMIS The Definition of homeless rule is now “final.” HUD issued a proposed rule a year and a half ago, made changes based on the comments received, and published the final rule on XX/XX/XXXX. The final rule applies to the ESG program HMIS is a proposed rule. That means that the regulatory text will be made available for public comment, HUD will make revisions, and the reg will only go into effect after it is published in its revised form -- as a final rule. Until the final regulation is published, the Notice from 2004 governs privacy and technical standards and the 2010 data standards govern data collection. The ESG and amended Con Plan regs are Interim Rules. That means they go into effect right away so the program can be operational. HUD will solicit public comments while the program is running, and ultimately make changes as needed by publishing a final rule.

8 Explanation of Rulemaking
Proposed rule – the regulation is published for public comment only Interim rule –the regulation is published for effect and for public comment through one publication Final rule – the regulation is published for effect PRESENTER: Ann A proposed rule means that the regulation is published for public comment for 60 days. After the public comment process ends, the Department compiles the comments, makes necessary changes, and publishes the rule as final. Until the regulation is published as final it does not apply to recipients of funds. An interim rule allows the Department to publish a rule for effect without going through the public comment process. The rule is published, recipients of funds must follow the rule as it is published, but the Department still seeks public comment for 60 days. Then the Department compiles the comments, makes necessary changes, and publishes the rule as final. A final rule is a regulation that is published for effect. It has already gone through the public comment process. Once it is published, recipients must follow the regulation. There is no additional time period for public comment. CONFIDENTIAL – INTERNAL USE ONLY

9 Emergency Shelter/Solutions Grants
FY 2011 Funding Allocation Emergency Shelter/Solutions Grants Amount Applicable Regulation First Allocation $160 million Emergency Shelter Grants Second Allocation $90 million Emergency Solutions Grants Total FY2011 Allocation $250 million To promote the purposes of the ESG program, and to follow the appropriations Act which directed HUD to spend at least $225 million on the Emergency Solutions Grants Program, HUD implemented the FY 2011 ESG program in two stages (or allocations) FY 2011 came in two allocations. This Chart shows the two stage allocation process that HUD is using for FY 2011 funds.  The Appropriations Act directed HUD to begin implementing the Emergency Solutions Grants program with  an increased FY2011 appropriation of at least $225 million.   This is up from the $160 HUD allocated to the Emergency Shelter Grants program in FY2010. HUD has decided to allocate a total of $250 in FY 2011 funds …..a $90 million (  70    % )increase over 2010.   The first Allocation of $160 million has been allocated and is being executed under the existing Emergency Shelter Grants regulation because the new rule was not yet published.  These funds will continue to follow the old Shelter grants regulation.    The additional  $90 million in Fy2011 will be allocated subject to the new Emergency Solutions Grants program interim regulation.       * The FY2011 Appropriation directed that HUD fund the ESG program for at least $225 million

10 Consolidated Plan Requirements
Recipients must complete a substantial amendment to the consolidated plan for: The second allocation Any reprogrammed funds from the initial FY allocation ***Any funds that are reprogrammed from the initial FY 2011 allocation are subject to the amended ESG regulation*** Before you can spend the second FY 2011 allocation, you will have to complete and have approved a substantial amendment to your Consolidated Plan defining your intended use of the money under the new regulations. HUD is developing guidance that will be published shortly to assist recipients in their preparation of their substantial amendments Recipients have the option to reprogram funds from the first allocation to activities allowed under the amended ESG rule. If recipients choose to reprogram funds, they should be aware that ALL of the new requirements will apply to the reprogrammed funds. This includes the spending restrictions on the second allocation of FY 2011 funds as will be discussed on the next slide. 10

11 Successful Implementation of ESG
Successful implementation will depend upon: Understanding the new regulations Designing and implementing new programs effectively, building on experience operating the Emergency Shelter Grants program and HPRP Cultivating effective collaboration between ESG recipients and their Continuums of Care (CoCs) Success will really depend on all of you: Understanding what the regulations require Designing your new programs based on what you learned in your Emergency Shelter Grants program and HPRP programs Establishing cooperative and collaborative relationships between ESG recipients and CoCs. 11

12 ESG Program Components and Activities
In this part of the presentation we are going to cover the first objective: making sure that you understand the ESG program’s components, and the activities that are eligible under each component.

13 5 Components & Administration
Serving… Those who are Homeless Those who are at risk of Homelessness 1. Street Outreach 2. Emergency Shelter 3. Homelessness Prevention 4. Rapid Re-housing Collecting Data On… 5. Homeless Management Information System (HMIS) Administration ESG consists of 5 components, plus administrative costs. The Street Outreach Component provides essential services needed to reach out to unsheltered homeless people and get them connected to shelter and needed services. The Emergency Shelter Component provides essential services to people in emergency shelters, and supports renovation and operation of emergency shelters. The Homelessness Prevention Component provides services to keep people from becoming homeless and having to live in an emergency shelter or on the streets. The Rapid Re-housing Component provides services to help people who are homeless move quickly into permanent housing and achieve housing stability. The Homeless Management Information System (HMIS) Component pays for the costs of operating and contributing to the CoC’s HMIS Administration is not one of the 5 components, but a 7.5% of ESG funds can be used for administrative activities. As you conceptualize your program, you need to think carefully about working within these components. The rest of the slides in this section of the Webinar will walk you through a high-level look at the activities that can be undertaken under each component. As we go through these, keep in mind that future webinars, as well as documents and tools on the HRE, will provide you with much more detail.

14 Why Components? Allows all interested parties to track and report use of funds against ESG program objectives, such as: Rapidly re-housing homeless persons Preventing homelessness Promotes reporting consistency with other homeless assistance programs, such as CoC and RHS Before we go into specifics about allowable activities under each component, it is important for you to understand why the program is structured around components in the first place. The HEARTH Act establishes the requirements that Continuums of Care report on the performance of ESG funded projects within their geographic area. HUD has aligned the components, where possible, with those in the Continuum of Care program to assist communities with streamlining reporting requirements and identifying consistent performance measures for like projects. HUD also anticipates these requirements will be consistent with the Rural Housing Stability Assistance Program.

15 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. Serves unsheltered homeless persons on the street 15

16 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) Or receiving services in a drop-in center or other day shelter. 16

17 Comparison of Essential Services
Street Outreach (unsheltered homeless persons) Emergency Shelter Services (sheltered homeless persons) Engagement Case Management Child Care Educational Services Employment Assistance / Training Emergency Health Care Outpatient Health Services Legal Services Life Skills Training Emergency Mental Health Care Mental Health Services Services for Special Populations Substance Abuse Treatment Transportation Both of the first two components, Street Outreach and Emergency Shelter, provide essential services to people who are homeless. The key difference between these two components pertains to the population that can be served. -- The Street Outreach component includes services targeted to homeless persons “staying on the streets” -- The Emergency Shelter component includes services targeted to homeless persons staying in emergency shelters The essential services permitted under each component are targeted to the needs of these different groups. As you can see in this side-by-side comparison, some activities seem similar under the two programs. But there are differences. For example, The term “Case Management” is used for both components, but the specific activities allowable under case management are different for the two groups. The case management activities under street outreach case management are designed to meet the emergency needs of those who are literally homeless and link them with shelter and services The case management activities under emergency shelter are geared to toward the somewhat longer-term needs of people who are sheltered, with a focus on providing the support those people will need to move to permanent housing situations. Health and mental health services are allowable under both components, but these services must be of an emergency nature for Street Outreach. Transportation and services for special populations are allowable for both components, but only when linked with other activities allowed under the component. Engagement is only an eligible activity under street outreach. 17

18 Street Outreach + 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 approved by HUD at or before the approval of the substantial amendment, which reflects prior commitments to street outreach and emergency shelter activities

19 3. Homelessness Prevention Component
Available to those 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 At risk of homelessness includes those who are at risk of homeless and also homeless under categories 2 and 3 of the homeless definition (and 4 where they also qualify as homeless under 2) Focus on the prevention and regaining stability piece to contrast this with RRH where the intent is to move them into permanent housing and ACHIEVE stability.

20 4. Rapid Re-Housing Component
Available to those who are 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 Homeless under category 1 (or 4 where they also qualify as homeless under category 1)

21 Housing Relocation & Stabilization
Allowable activities for both Homelessness Prevention and Rapid Re-housing components: 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 You probably noticed that both the homelessness prevention and rapid re-housing components involved the same eligible activities. Relocation and Stabilization Services Short- and Medium-Term Rental Assistance This and the next few slides talk about those activities. The Housing relocation and stabilization activities allow for financial assistance and services. ESG funds cannot be used to provide financial assistance for a purpose and time period supported by another public source – similar to the cost-type rule that you may be familiar with from HPRP. *No financial assistance to a household for a purpose and time period supported by another public source.

22 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 = 3 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 There are lots of details to learn about rental assistance activities under ESG. Here, we’ll just hit some of the highlights. An upcoming webinar will provide much more detail.

23 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 6 months of arrears) Rental assistance must be used for permanent housing that meets certain standards– Rent within FMRs Reasonable rent All housing must Meets minimum habitability standards (not HQS) Has a rental assistance agreement and acceptable lease in place Must not provide assistance if the household is already supported by rental assistance from another subsidy program for the same time period, except for arrears.

24 5. HMIS Component Eligible costs for recipients that are HMIS Lead Agencies: Hosting and maintaining software or data Backing up, recovering, or repairing software or data Upgrading, customizing, and enhancing the HMIS Integrating and warehousing data Our last component involves data entry into, and management of, the Homelessness Management Information System (HMIS) ESG funds can be used by HMIS lead agencies to support a range of costs related to operating an effective HMIS system.

25 5. HMIS Component Eligible costs for recipients that are HMIS Lead Agencies: Administering the HMIS Reporting Conducting training on using the HMIS [slide is self explanatory…no speaker notes expected]

26 5. HMIS Component Eligible costs for all recipients* and subrecipients include: Computer hardware, software, and software licenses Office space, utilities, and equipment Obtaining technical support Salaries for HMIS operation * Except States ESG funds can also be used to support a range of costs related to contributing data to an HMIS (or comparable database)

27 5. HMIS Component Eligible costs for all recipients* and subrecipients include: Staff travel (training and program participant intake) Participation fees charged by the HMIS Lead * Except States

28 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 Although administrative activities are not a component of the ESG program, they are necessary to ensure effective implementation of the other components. [Slide is self-explanatory; no speaker notes anticipated].

29 Administrative Activities
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 For example, a case manager in an emergency shelter may have his or her staff salary charged to the essential services line item; although, the executive director of the agencies who generally oversees all activities within the agency would be charged to administrative costs.

30 Administrative Activities Amount
Up to 7.5% of grant may be used for administrative costs The 7.5% is calculated based on the entire FY allocation. IDIS will be set to allow draws up to 7.5% of the entire FY 2011 allocation. Under ESG, up to 7.5% of the grant can be used for administrative costs. State recipient’s must shar In FY 2011, funding has been provided in two allocations. For the first allocation, you have been working under a 5% cap. Because the 7.5% figure will apply to the entire FY 2011 grant, including both allocations, you will be able to apply that 7.5% amount to the combination of your first and second allocations. IDIS IDIS has been configured to allow draws up to 7.5 percent of the entire FY 2011 allocation and will not allow recipients to draw more than 7.5% for admin. 30 30

31 ESG Program Requirements

32 Centralized/Coordinated Assessment
Purpose of Coordination Promote consistent standards Avoid duplicative/unnecessary assistance Promote strategic targeting of homeless assistance resources Used to initially assess the eligibility and needs of each individual or family who seeks assistance ** Participation in a centralized or coordinated assessment is not required until the CoC Program rule is published as final ** A key program requirements is the need for ESG recipients and subrecipients to participate in a centralized/coordinated assessment. This requirement does not go into effect until the publication of the final CoC rule, in part because many CoCs do not currently have centralized or coordinated assessment systems; therefore, recipients and subrecipients are not required to participate in a coordinated or centralized assessment system. If recipients and subrecipients are located in a CoC covered by a coordinated or centralized assessment system they may participate. 32

33 Other Program Requirements
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 There are numerous other program requirements that we won’t go into any detail about, but do want to raise so you’ll be aware of them and be on the look-out for additional information. A recipient must coordinate with Continuum’s of Care to allocate funds and performance measurement standards. A recipient must identify in the Consolidated Plan, including: Uses of funds Standards for amounts and types of assistance Projects and uses of funds must be consistent with the approved consolidated plan. At all points, recipients and subrecipients must be working to connect participants with mainstream resources. Re-evaluation of program participants ensures that limited ESG funds are going to those who need it most. Frequency of re-evaluation will depend on the type of service provided, with program participants being served by homelessness prevention being re-evaluated every 3 months, and program participants who have been rapidly re-housed are required to be re- evaluated at least annually Recipients will be required to have written standards on a wide range of topics. 33

34 Other 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 via e-snaps Dollar for dollar match is required, but can be cash or in kind. There are exceptions for Territories and first $100,000 of State grants, just as in the Emergency Shelter Grants program. Recipients must participate in HMIS, use IDIS for beneficiary data and draws, and must use e-snaps for performance reporting. More detail will be provided at a later date, but you should know now that in the first year performance reporting will be limited. Performance reporting will rely on HMIS once all recipients and subrecipients are using HMIS. 34

35 Next Steps in Implementing the ESG Program

36 Key Implementation Actions
Review new regulations and materials posted on the HRE to understand new opportunities and obligations under the amended ESG Initiate planning and build relationships to ensure appropriate consultation with CoCs There are four main things to tackle right away. First, review the new regulations and materials posted on the HRE to understand what is possible under the amended ESG program. Second, you need to start planning your program and building relationships between grantees and CoCs. Third, start the planning process for submitting your substantial amendment to the Consolidated plan. Fourth, start thinking about the challenges you are going to face, and how you might overcome them. The next few slides identify some of the questions you may want to ask yourselves. 36

37 Key Implementation Actions
Initiate planning for submission of a “Substantial Amendment” to the recipient’s Consolidated Plan Identify potential implementation challenges and develop strategies to address them There are four main things to tackle right away. First, review the new regulations and materials posted on the HRE to understand what is possible under the amended ESG program. Second, you need to start planning your program and building relationships between grantees and CoCs. Third, start the planning process for submitting your substantial amendment to the Consolidated plan. Fourth, start thinking about the challenges you are going to face, and how you might overcome them. The next few slides identify some of the questions you may want to ask yourselves. 37

38 Implementation Questions
What can we (as a community) learn 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? [Slide is self-explanatory; no speaker notes anticipated]. 38

39 Implementation Questions
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? [Slide is self-explanatory; no speaker notes anticipated]. 39

40 Additional Resources Resources on www.hudhre.info include:
The McKinney-Vento Act, as amended by the HEARTH Act All published program regulations User Guides Webinar podcasts At-a-glance charts and sample forms Link to the ESG Help Desk [NOTE TO HUD: This is a “placeholder list” and will need to be adjusted when we know exactly what is going to be available]


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