Emergency Solutions Grants: Funding, Eligibility, and Impact on Homelessness

Emergency Solutions Grants (ESG) are a vital federal resource. Administered by the U.S. Department of Housing and Urban Development (HUD), these grants empower communities to comprehensively address homelessness. The program aims to help individuals and families quickly regain stability in permanent housing after facing a housing crisis or homelessness.  

The core purpose of the ESG program is to identify sheltered and unsheltered homeless persons, as well as those at risk of homelessness. It then provides the necessary support and services to help them transition out of crisis and into stable living situations. The consistent emphasis on "quickly regaining stability in permanent housing" highlights a strategic focus beyond temporary shelter, underscoring the importance of long-term solutions. This resource offers a thorough exploration of the ESG program, clarifying its objectives, functions, beneficiaries, and its role in the national strategy to combat homelessness.

Defining Emergency Solutions Grants: Purpose and Foundations

The Emergency Solutions Grants program is a cornerstone of the federal response to homelessness. It provides essential funding to communities nationwide, aiming to address immediate crises and build pathways to long-term housing stability.

Official Purpose and Goals of the ESG Program

The ESG program's primary purpose is to assist individuals and families experiencing or at risk of homelessness to quickly regain stability in permanent housing. This involves several key goals:

• Identifying and engaging sheltered and unsheltered homeless persons, and those at imminent risk of losing housing.
• Providing services to help these individuals and families secure and maintain permanent housing.  
• Improving the number and quality of emergency shelters.
• Supporting shelter operational costs and essential services for residents.
• Actively working to prevent homelessness.
• Facilitating rapid re-housing for those who have become homeless.

Legislative Roots: From Emergency Shelter Grants to the HEARTH Act

The ESG program's foundation is the McKinney-Vento Homeless Assistance Act of 1987 (P.L. 100-77). This act first authorized federal support for homeless assistance programs. Initially, the program was known as the Emergency Shelter Grants Program, focusing on funding emergency shelters and related support services.

A significant transformation occurred with the Homeless Emergency Assistance and Rapid Transition to Housing (HEARTH) Act of 2009 (P.L. 111-22). The HEARTH Act reauthorized and substantially amended the McKinney-Vento programs. It renamed the Emergency Shelter Grants Program to the Emergency Solutions Grants Program, reflecting a shift in philosophy and scope.

The HEARTH Act expanded eligible activities, placing a stronger emphasis on homelessness prevention and rapid re-housing. This evolution signifies a move from primarily managing homelessness through temporary shelter towards a more proactive, comprehensive approach. The term "Solutions" implies a strategic, outcome-focused approach aimed at ending, not just managing, homelessness.

Core Components: How ESG Deliver Support

The Emergency Solutions Grants program is structured around five main program components, plus an allowance for administrative activities. Each component addresses different facets of a housing crisis, offering a flexible framework for communities to tailor responses to local needs under HUD regulations.

Street Outreach (§ 576.101): Connecting with Unsheltered Populations

The Street Outreach component funds essential services to locate, identify, and build relationships with unsheltered homeless individuals and families. These are individuals living in places not meant for human habitation.

Eligible activities include:

• Engagement (initial contact and assessment).
• Case management (coordinating services, developing housing plans).
• Providing emergency health and mental health services.
• Transportation to shelters or service facilities. This component is often the first point of contact for highly vulnerable individuals.

Emergency Shelter (§ 576.102): Funding for Operations, Services, and Physical Improvements

This component supports emergency shelters and essential services for homeless individuals and families. Eligible activities are broad:

• Renovation, Major Rehabilitation, or Conversion: Improving existing buildings for use as emergency shelters (new construction is not included). Shelters assisted with ESG funds must operate for a minimum of 3 or 10 years, depending on the renovation cost and type.
• Essential Services: Services for shelter residents like case management, childcare, education, employment assistance, outpatient health services, legal services, life skills training, mental health services, and substance abuse treatment.
• Shelter Operations: Covering daily operational costs such as rent, utilities, security, food, and furnishings.
• Hotel/Motel Vouchers: Short-term hotel or motel stays if no appropriate emergency shelter is available.

Homelessness Prevention (§ 576.103): Keeping Individuals and Families Housed

The Homelessness Prevention component aims to prevent individuals and families at imminent risk of homelessness from losing their housing and help them regain stability.

Assistance can include:

• Housing Relocation and Stabilization Services: Housing search and placement, case management, landlord mediation, legal services, and credit repair.
• Financial Assistance: Short-term and medium-term rental assistance, rental arrears, application fees, security/utility deposits, utility payments, and moving costs. Eligibility typically requires household income at or below 30% of the Area Median Income (AMI).

Rapid Re-Housing (§ 576.104): Pathways to Permanent Housing

Rapid Re-Housing assists individuals and families currently experiencing homelessness to move quickly into permanent housing and achieve stability.

Eligible costs mirror those of homelessness prevention:

• Housing Relocation and Stabilization Services.
• Financial Assistance: Including short-term and medium-term rental assistance and help with deposits and fees. The focus is on minimizing time spent homeless and connecting individuals to resources for long-term housing retention.

Homeless Management Information System (HMIS) (§ 576.107): The Role of Data

ESG funds can pay for costs associated with participating in and contributing data to the local Continuum of Care’s (CoC) Homeless Management Information System. HMIS is a computerized data collection system storing client-level information about persons accessing homeless services.

This data is crucial for:

• Understanding the scope of homelessness.
• Coordinating services.
• Reducing duplication.
• Reporting to HUD.
• Evaluating program effectiveness. The inclusion of HMIS as a fundable component highlights the federal emphasis on data-driven decision-making.

Administrative Activities (§ 576.108): Supporting Program Delivery

Recipients can use up to 7.5% of their annual ESG grant for administrative activities. These include general management, program oversight, activity coordination, and reporting to HUD. State recipients must share some administrative funds with their local government subrecipients and may share with nonprofit subrecipients.

The following table provides a summary of these core components:

Table 1: Overview of ESG Program Components and Primary Eligible Activities

This structured, flexible approach allows communities to allocate ESG resources strategically.

Who Qualifies for Assistance: ESG Eligibility for Individuals and Families

Emergency Solutions Grants funds target individuals and families currently homeless or at serious risk of becoming homeless. HUD has detailed eligibility criteria, primarily in 24 CFR 576.2, to ensure aid reaches those most in need. ESG recipients and subrecipients are responsible for determining and documenting participant eligibility based on these federal regulations and any local standards.

Understanding "Homeless" Status under ESG Rules (24 CFR 576.2)

The definition of "homeless" under ESG is divided into four categories:

• Category 1: Literally Homeless: Individuals and families lacking a fixed, regular, and adequate nighttime residence. This includes those in public/private places not meant for human habitation (e.g., cars, parks), supervised shelters, or exiting institutions after a short stay if previously homeless. Generally eligible for Street Outreach, Emergency Shelter, and Rapid Re-Housing.
• Category 2: Imminent Risk of Homelessness: Individuals and families who will lose their primary nighttime residence within 14 days of applying, with no subsequent residence identified and lacking resources for other permanent housing. Typically eligible for Emergency Shelter and Homelessness Prevention. For Prevention, income must generally be at or below 30% AMI.
• Category 3: Homeless Under Other Federal Statutes: Unaccompanied youth under 25, or families with children/youth, not qualifying under other definitions but meeting homeless definitions under other federal statutes. They must also meet criteria like no recent lease, persistent instability, and expected continuation of such status due to various barriers. Eligible for Emergency Shelter and Homelessness Prevention, with the <30% AMI income limit for Prevention.
• Category 4: Fleeing/Attempting to Flee Domestic Violence, Dating Violence, Sexual Assault, Stalking, or Other Dangerous Conditions: Individuals or families fleeing such conditions related to violence within their primary residence or making them afraid to return, with no other residence and lacking resources for permanent housing. Eligible for Emergency Shelter, Rapid Re-Housing, and Homelessness Prevention. The <30% AMI limit generally applies for Prevention.

The detailed categories acknowledge that homelessness is not a monolithic experience and allow for targeted interventions.

Defining "At Risk of Homelessness" (24 CFR 576.2)

ESG also serves those "at risk of homelessness." This applies to individuals or families with annual income below 30% AMI, lacking immediate resources to prevent homelessness, AND meeting specific conditions. These conditions include multiple moves due to economic reasons, living in another's home due to hardship, receiving an eviction notice, or living in severely overcrowded housing. Those "at risk" are eligible for Homelessness Prevention assistance only.

Income Considerations for Program Participants

Income is a key factor for some ESG components, especially Homelessness Prevention. Participants generally must have incomes at or below 30% of the Area Median Income (AMI). These limits vary by family size and geographic area. For Rapid Re-Housing, an income test at entry is not usually the primary determinant. This differentiation allows for strategic resource allocation.

General Documentation and Verification for Eligibility

ESG recipients and subrecipients must establish and apply written standards for assistance. This includes maintaining records documenting participant eligibility. While HUD provides guidelines, specific documentation forms may be defined by the state or local entity administering funds.

The following table summarizes the main eligibility categories:

Table 2: Eligibility Categories for Individuals and Families Seeking ESG Assistance

Organizations on the Front Lines: ESG Recipient and Subrecipient Eligibility

The Emergency Solutions Grants program uses a tiered system. HUD provides funds to direct recipients (grantees), who often distribute them to subrecipients for direct service delivery.

Direct Recipients (Grantees from HUD)

HUD awards ESG funds directly to specific governmental entities:

• State governments.
• Metropolitan cities (populations of 50,000+).
• Urban counties (populations of 200,000+, excluding metro cities within).
• U.S. Territories. These entities receive ESG funding via formula allocation, not typically through competitive applications for these base grants.

Subrecipients (Receive funds from Direct Recipients)

Direct recipients make ESG funds available to organizations implementing program activities.

• State recipients must subgrant all ESG funds (except for allowable administrative/HMIS costs) to units of general purpose local government and/or private nonprofit organizations. This ensures funds reach the local level.
• Metropolitan cities, urban counties, and territories may subgrant funds to private nonprofits or implement programs directly.
• Units of general purpose local government (direct recipients or subrecipients of state funds) may further subgrant ESG funds to Public Housing Agencies (PHAs) and Local Redevelopment Authorities (LRAs) under certain conditions.

Eligible subrecipients are typically units of general purpose local government or private nonprofit organizations with 501(c)(3) status.

Essential Criteria for Organizations to Participate (as Subrecipients)

Organizations seeking to become ESG subrecipients must meet several criteria:

• Eligible Entity Type: Unit of general purpose local government or private nonprofit (typically 501(c)(3)).
• Continuum of Care (CoC) Membership: Generally required to be members of their local CoC.
• HMIS Participation: Must participate in or be ready to use the CoC’s Homeless Management Information System (HMIS). This ensures coordinated, data-driven service.
• Sponsorship/Experience: First-time private nonprofit applicants may need sponsorship. Experienced nonprofits may apply independently.
• Program Compliance: Must demonstrate capacity to comply with all ESG program requirements (financial management, eligible activities, recordkeeping, reporting).
• Written Standards: Must have and adhere to written standards for providing ESG assistance.
• Certifications: Often required to provide certifications (consistency with consolidated plan, citizen participation, non-discrimination).

Securing ESG Funding: The Application Process for Organizations

The path to ESG funding differs for direct HUD grantees versus potential subrecipients.

For Direct HUD Grantees (States, Metropolitan Cities, Urban Counties, Territories)

These entities primarily apply for ESG funds through the Consolidated Planning process. This HUD requirement applies to jurisdictions receiving formula funding under several Community Planning and Development (CPD) programs.

The process involves:

1. Needs Assessment: Jurisdictions assess affordable housing and community development needs, including homelessness.
2. Strategic Plan: A 3- to 5-year Consolidated Plan outlines strategies to address identified needs.  
3. Annual Action Plan: Details specific activities for the year, specifying ESG fund use. The ESG application is part of this plan.
4. Citizen Participation: Meaningful public input is required throughout the process.
5. Submission to HUD: Plans are submitted to HUD, typically via the eCon Planning Suite in IDIS. Funding is allocated via formula, not a competitive Notice of Funding Opportunity (NOFO) for these entitlement grants.

For Subrecipients (Local Governments, Non-Profits)

Local government agencies and private nonprofits apply to the direct ESG recipient for their area (e.g., state housing agency, county department). This is not a direct application to HUD.

Direct recipients issue their own Notices of Funding Availability (NOFAs) or RFPs. The process varies but generally involves:

• Demonstrating organizational capacity and experience.
• Providing evidence of community need.
• Aligning projects with CoC priorities and the Consolidated Plan.
• Meeting all ESG program requirements.
• Some recipients may require attendance at application workshops. This decentralized approach allows tailoring resources to local needs but can lead to varied application processes.

Key Systems and Registrations

Organizations interacting with federal funding, especially for competitive HUD opportunities, generally need to register in SAM.gov. Competitive HUD NOFOs are posted on Grants.gov. Subrecipient ESG opportunities are typically announced by the state or local grantee.

The Financial Landscape of ESG: Allocation, Matching, and Timelines

Understanding ESG's financial mechanics—allocation, matching, and timelines—is crucial.

How HUD Allocates ESG Funds to Communities

ESG is a non-competitive formula grant. Funding is based on a predetermined formula:

1. Territorial Set-Aside: HUD sets aside up to 0.2% (not less than 0.1%) of the total appropriation for U.S. territories.
2. Allocation to States, Cities, and Counties: Remaining funds are allocated based on the percentage of the prior year's Community Development Block Grant (CDBG) formula allocation each jurisdiction received. This links ESG funding to broader community development indicators.
3. Minimum Allocation Threshold: If a city's or county's ESG allocation is less than 0.05% of the total appropriation, it's added to the state's allocation. Direct recipients must consult with their local CoC(s) on how to further allocate funds to projects and subrecipients.

Matching Fund Requirements (24 CFR 576.201)

Most ESG recipients must provide a dollar-for-dollar match from non-federal sources.

• Metropolitan city and urban county recipients must match their ESG grant with cash or in-kind contributions (donated buildings, materials, volunteer services).
• State recipients must match all but $100,000 of their award and pass this exception's benefit to subrecipients least able to provide a match.
• Territories are exempt from matching.

Timelines for Obligating and Expending Grant Funds (24 CFR 576.203)

HUD imposes strict deadlines:

• Obligation Deadlines:
  • Metropolitan cities, urban counties, and territories: 180 days from HUD signing the grant agreement (excluding admin costs).
  • State recipients: 60 days from HUD signing. If a state subgrants to a local government, that subrecipient has 120 days from the state's obligation to obligate funds.
• Expenditure Deadline: All ESG funds must be expended within 24 months after HUD signs the grant agreement with the direct recipient. These deadlines incentivize rapid fund deployment but can pressure communities, potentially leading to rushed planning or challenges for smaller subrecipients.

National Impact: ESG's Role in Addressing Homelessness Across the U.S.

The ESG program is a significant part of the national strategy to prevent and end homelessness, enabling communities to offer a range of services.

Statistical Overview of ESG's Reach and Contribution

Annually, ESG directly supports hundreds of thousands of people. Budget justifications show ESG supporting over 350,000 to 450,000 persons in emergency shelters each year. In FY 2019, HUD allocated $280 million to 366 recipients. Requested amounts for subsequent years like FY2021 ($280 million) and FY2024 ($290 million) have been similar.

Homeless Assistance Grants (HAG), including ESG and the CoC program, are key to addressing homelessness. While overall homelessness declined 12% between 2010-2019, recent HUD reports show a 12% increase between January 2022-2023, with over 653,000 people homeless on a single night. This rise is attributed to increasing housing costs, affordable housing shortages, and the end of pandemic aid. ESG remains a primary "first response" for many.

The ESG-CV Response to the COVID-19 Pandemic

The COVID-19 pandemic posed unprecedented challenges. The CARES Act appropriated $4 billion in supplemental ESG funding (ESG-CV) "to prevent, prepare for, and respond to coronavirus" among homeless individuals and families.

ESG-CV funds, with HUD waivers for flexibility, focused on non-congregate shelter (hotels/motels), expanded street outreach, and continued prevention/rapid re-housing. California enrolled nearly 96,000 people in ESG-CV services, over half in emergency shelter. Nationally, the House America initiative saw communities dedicate over $450 million in ESG-CV funds to re-housing. This large funding infusion tested the ESG framework's adaptability.

Illustrative Examples of Impact

While comprehensive national ESG success stories are not readily compiled, impacts are seen through various initiatives:

• The Emergency Housing Voucher (EHV) program, often paired with ESG-funded services, shows success. King County, WA, leased 100% of its 762 EHVs. Michigan quickly allocated EHVs due to strong CoC partnerships. 
• Locally, Benilde Hall in Kansas City received a $67,000 ESG grant to serve 500 adult males experiencing homelessness and co-occurring disorders.
• The earlier Homelessness Prevention and Rapid Re-Housing Program (HPRP) demonstrated the effectiveness of prevention and rapid re-housing strategies, offering a model for ESG outcomes. Fluctuations in national homelessness statistics suggest ESG's impact is influenced by broader economic and housing market factors.

Accountability and Oversight: Reporting Requirements for ESG Programs

A robust accountability system ensures ESG funds are used effectively and compliantly. Data collection and reporting are central.

The Central Role of the Homeless Management Information System (HMIS)

HMIS participation is a cornerstone of ESG. HMIS is a local IT system collecting client-level data on homeless individuals and services. Key aspects include:

• Mandatory Participation: ESG recipients and subrecipients generally must participate in the local CoC's designated HMIS.
• Data Collection: HMIS records demographics, service needs, services provided, and housing outcomes.
• HUD Data Standards: National HMIS Data Standards ensure consistent data collection for aggregation and analysis.
• Program Evaluation: HMIS data is critical for assessing ESG intervention effectiveness.

Key Reporting Mechanisms

Several systems and reports are used for ESG oversight:

• Consolidated Annual Performance and Evaluation Report (CAPER): Direct ESG recipients report annually to HUD on fund use and accomplishments through the CAPER. This report covers all of a jurisdiction's CPD formula grants and is typically due 90 days after the program year ends. ESG data must align with HMIS Data Standards.
• Integrated Disbursement and Information System (IDIS): IDIS is HUD's primary system for grantees to draw down ESG funds. It also houses the eCon Planning Suite for Consolidated Plans and Annual Action Plans. IDIS provides real-time program and funding information.
• Sage HMIS Reporting Repository (Sage): Since October 2017, ESG recipients submit program accomplishment data (CSV files from HMIS) directly into Sage for CAPER reporting, replacing the older eCart tool. This streamlines data transfer and improves accuracy. ESG-CV specific reports were also submitted quarterly in Sage.

Data to be Reported

Data reported to HUD generally includes:

• Number and demographics of homeless individuals and families served.
• Client-reported causes of homelessness.
• Expenditures by ESG activity type.
• Outcomes related to housing stability (e.g., moves to permanent housing). Specific data elements are defined in HUD's HMIS Data Standards. This framework, while providing rich data, places significant administrative responsibility on grantees.

Conclusion: The Continuing Significance of Emergency Solutions Grants

The Emergency Solutions Grants program is a vital federal initiative. It empowers communities to provide a critical first response to those facing homelessness or its imminent threat. Through components like street outreach, emergency shelter, prevention, rapid re-housing, and HMIS, ESG enables a flexible, structured approach to housing crises and fostering stability.

Ongoing challenges like affordable housing shortages and economic uncertainties highlight ESG's persistent importance. The program's evolution, especially via the HEARTH Act, reflects a shift towards comprehensive, lasting solutions. ESG, while focused on "emergency" aid, is intertwined with long-term housing stability.

Looking forward, collaborative, well-funded emergency solutions are essential. ESG's success depends on federal investment, HUD guidance, and the dedication of state/local governments, nonprofits, CoCs, and service providers. As communities tackle homelessness, ESG will remain a crucial resource in ensuring everyone has a safe, stable home.

Frequently Asked Questions