HUD Publishes Coordinated Entry Requirements for Homeless Assistance Programs

Yesterday, HUD published long-awaited guidance (Notice CPD-17-01) establishing the additional requirements for the development and implementation of a “centralized or coordinated assessment system” (i.e., “coordinated entry” or “coordinated entry process”) for recipients and subrecipients of the Continuum of Care (CoC) and Emergency Solutions Grants (ESG) programs.

The coordinated entry processes are intended to help communities prioritize people who are most in need of homeless assistance and help grantees and stakeholders strategically allocate their resources by providing information about local service needs and gaps. Each CoC must establish or update its coordinated entry process in accordance with the 2012 CoC interim final rule and this notice by January 23, 2018.

Once the coordinated entry process is established, updated and/or operationalized by CoC program recipients and subrecipients, HUD will expect the coordinated entry process to be used for all ESG programs and projects within the CoC’s geographic area. However, HUD does not require victim service providers under ESG to use the CoC’s coordinated entry process.

Additional analysis of this HUD guidance will be provided to members in a forthcoming edition of the NAHRO Monitor.

Regulatory Freeze Memo Issued

On January 20, the Trump Administration issued a “Regulatory Freeze Pending Review” memo that applies to all Federal agencies, including the U.S. Department of Housing and Urban Development (HUD). This memo is similar to memos issued by previous administrations as they come into office, and NAHRO had expected this regulatory freeze.

Generally, the regulatory freeze requires agencies to withdraw any regulations that have not yet been published in the Federal Register and to extend the effective date by 60 days of any regulations that have not become effective as of January 20, 2017. The Director of the Office of Management and Budget (OMB) can issue exceptions to the regulatory freeze in emergency situations and to address urgent health, safety, financial, or national security issues.

The regulatory review not only applies to regulations but also any “guidance document.” A “guidance document” is any substantive action or an agency statement that states a policy on a statutory, regulatory, or technical issue that is normally published in the Federal Register.

NAHRO will continue to monitor the effects of the regulatory freeze and has reached out to HUD staff on how this regulatory freeze will affect specific regulations. As more information becomes, available NAHRO will share it with our members through The NAHRO Blog and the Monitor.

For any specific questions or concerns, please contact Georgi Banna, NAHRO’s Director of Policy and Program Development, at gbanna@nahro.org. As always for the most up-to-date information of the affordable housing and community development regulations and legislation, follow The NAHRO Blog and check the NAHRO website.