HUD Guidance on Sub-awarding Homeless Assistance Funds to PHAs and Local Redevelopment Authorities

Today, the HUD Office of Community Planning and Development (CPD) published a new notice (CPD-17-01) that provides guidance on how Emergency Solutions Grants (ESG) Program funds can be sub-awarded to Public Housing Agencies (PHAs) and Local Redevelopment Authorities (LRAs). On July 29, 2016, President Obama signed into law the Housing Opportunity Through Modernization Act of 2016 (HOTMA) which included language, first proposed by NAHRO, that amended the McKinney-Vento Homeless Assistance Act (42 U.S. 11373(C)) to permit local governments receiving ESG funding to sub-award their ESG funds to PHAs and LRAs for eligible ESG activities. This change saves grantees from having to go through a costly and time-consuming procurement process if they wish to devolve their funds to any PHA or LRA. This change became effective upon enactment of HOTMA last year and required no regulatory rulemaking. This new notice provides additional guidance on the allowable sub-awards to PHAs and LRAs and the key requirements (e.g. consistency with the Consolidated Plan) that apply to sub-awarded funds

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.