.
The HUD Homeless Assistance Grants:
Distribution of Funds
Libby Perl
Specialist in Housing Policy
June 22, 2011
Congressional Research Service
7-5700
www.crs.gov
RL33764
CRS Report for Congress
P
repared for Members and Committees of Congress
c11173008
.
The HUD Homeless Assistance Grants: Distribution of Funds
Summary
Currently, the U.S. Department of Housing and Urban Development (HUD) distributes four
Homeless Assistance Grants, each of which provides funds to local communities to finance a
range of housing and supportive services options for homeless persons. These four grants—the
Emergency Shelter Grants (ESG) program, the Supportive Housing Program (SHP), the Shelter
Plus Care (S+C) program, and the Section 8 Moderate Rehabilitation for Single Room
Occupancy Dwellings (SRO) program—were enacted as part of the McKinney-Vento Homeless
Assistance Act (P.L. 100-77).
The way in which the Homeless Assistance Grants are distributed will change, probably in
FY2012, as the result of legislation enacted in the 111th Congress. The Homeless Assistance
Grants were reauthorized as part of the Helping Families Save Their Homes Act (P.L. 111-22).
The changes in P.L. 111-22 will have repercussions for the makeup of the Homeless Assistance
Grants, the way in which funds are distributed to grantees, and the purposes for which grantees
may use funds. The changes in P.L. 111-22 technically became effective as of November 20, 2010
(the law specified that provisions would take effect at the earlier of 18 months after enactment or
three months from the date on which HUD publishes final regulations). However, HUD has not
issued regulations, and has stated that until new regulations become effective, the current
regulations governing the Homeless Assistance Grants continue in place. As a result, this report
continues to describe how HUD currently distributes the four existing Homeless Assistance
Grants.
HUD distributes the four Homeless Assistance Grants annually to eligible applicants, which
include states, metropolitan areas, counties, nonprofit organizations, and public housing
authorities. Funds for the ESG program are used primarily for the short-term needs of homeless
persons, such as emergency shelter, while the SHP, S+C, and SRO programs address longer-term
transitional and permanent housing needs. HUD uses one method to distribute funds for the ESG
program and another method to distribute funds for the SHP, S+C, and SRO programs.
The ESG program distributes funds to states, counties, and metropolitan areas using the
Community Development Block Grant (CDBG) program formula. In general, states and
communities receive the same proportion of ESG funds that they received in CDBG funds the
previous fiscal year. After they receive funds, states and communities then distribute them to
homeless service providers, including nonprofit organizations and local government entities.
The SHP, S+C, and SRO grants are distributed through a competitive process called the
Continuum of Care (CoC) application system (these three grants are sometimes referred to as the
“competitive grants”). Through the CoC process, representatives from local community
organizations work collaboratively to develop a plan for addressing homelessness in their area.
They then determine which homeless services providers in the community should receive funding
and submit a unified application to HUD. HUD then uses a multi-step process to award the
grants. This involves both a formula aspect, through which HUD determines community need
using the CDBG formula, and a competitive aspect, through which HUD assigns points for
various elements included in the CoC application. This report describes the allocation of the
Homeless Assistance Grants, as well as separate HUD funding for homelessness activities—the
Homelessness Prevention and Rapid Re-Housing Program and Section 8 vouchers for homeless
individuals and families proposed in the President’s FY2011 and FY2012 budgets.
Congressional Research Service
.
The HUD Homeless Assistance Grants: Distribution of Funds
Contents
Introduction ................................................................................................................................ 1
The Role of Congress and HUD in the Funding Process .............................................................. 2
The Emergency Shelter Grants Program (ESG) ........................................................................... 5
Distribution of ESG Funds .................................................................................................... 6
The Three Competitive Homeless Assistance Grants ................................................................... 7
The Supportive Housing Program (SHP) ............................................................................... 7
The Single Room Occupancy Program (SRO) ....................................................................... 8
The Shelter Plus Care Program (S+C) ................................................................................... 9
Distribution of the Competitive Grants and the Continuum of Care (CoC) Process .................... 10
The Continuum of Care....................................................................................................... 11
HUD Determination of CoC Pro Rata Need......................................................................... 12
Renewal of SHP and S+C Projects ...................................................................................... 14
The Competition for New Project Funding .......................................................................... 14
Special Activities ...................................................................................................................... 17
Rapid Re-Housing Demonstration Program......................................................................... 17
The Homelessness Prevention and Rapid Re-Housing Program ........................................... 18
Housing Vouchers for Persons Who Are Homeless .............................................................. 19
Reauthorization of the McKinney-Vento Homeless Assistance Grants ....................................... 22
Consolidation of the Competitive Homeless Assistance Grants............................................ 22
Definition of “Homeless Individual” and “Chronically Homeless Person” ........................... 24
Homelessness Prevention .................................................................................................... 25
Rural Homelessness ............................................................................................................ 26
Other Issues Regarding the Homeless Assistance Grants ........................................................... 26
Renewals of the Competitive Homeless Assistance Grants .................................................. 26
The Role of the Community Development Block Grant Formula ......................................... 28
Figures
Figure 1. Distribution of the HUD Homeless Assistance Grants................................................. 21
Figure 2. FY2010 Percentage Allocation of Competitive Grants ................................................ 28
Tables
Table 1. Funding for Homeless Assistance Grants, FY1987-FY2011 .......................................... 3
Table 2. Characteristics of the SHP, S+C, and SRO Programs.................................................... 10
Contacts
Author Contact Information ...................................................................................................... 30
Congressional Research Service
.
The HUD Homeless Assistance Grants: Distribution of Funds
Introduction
Homelessness in America has always existed, but it did not come to the public’s attention as a
national issue until the 1970s and 1980s, when the characteristics of the homeless population and
their living arrangements began to change. Throughout the early and middle part of the 20th
century, homelessness was typified by “skid rows”—areas with hotels and single-room
occupancy dwellings where transient single men lived.1 Skid rows were usually removed from the
more populated areas of cities, and it was uncommon for individuals to actually live on the
streets.2 Beginning in the 1970s, however, the homeless population began to grow and become
more visible to the general public. According to studies from the time, homeless persons were no
longer almost exclusively single men, but included women with children; their median age was
younger; they were more racially diverse (in previous decades the observed homeless population
was largely white); they were less likely to be employed (and therefore had lower incomes); they
were mentally ill in higher proportions than previously; and individuals who were abusing or had
abused drugs began to become more prevalent in the population.3
A number of reasons have been offered for the growth in the number of homeless persons and
their increasing visibility. Many cities demolished skid rows to make way for urban development,
leaving some residents without affordable housing options.4 Other possible factors contributing to
homelessness include the decreased availability of affordable housing generally, the reduced need
for seasonal unskilled labor, the reduced likelihood that relatives will accommodate homeless
family members, the decreased value of public benefits, and changed admissions standards at
mental hospitals.5 The increased visibility of homeless people was due, in part, to the
decriminalization of actions such as public drunkenness, loitering, and vagrancy.6
In the 1980s, Congress first responded to the growing prevalence of homelessness with several
separate grant programs designed to address the food and shelter needs of homeless individuals.7
Then, in 1987, Congress enacted the Stewart B. McKinney Homeless Assistance Act (McKinney
Act), which created a number of new programs to comprehensively address the needs of
homeless people, including food, shelter, health care, and education (P.L. 100-77). The act was
later renamed the McKinney-Vento Homeless Assistance Act (McKinney-Vento) in P.L. 106-400
after its other prominent sponsor, Bruce F. Vento.8
1 Peter H. Rossi, Down and Out in America: The Origins of Homelessness (Chicago: The University of Chicago Press,
1989), pp. 20-21, 27-28.
2 Ibid., p. 34.
3 Ibid., pp. 39-44.
4 Ibid., p. 33.
5 Ibid., pp. 181-194, 41. See, also, Martha Burt, Over the Edge: The Growth of Homelessness in the 1980s (New York:
Russell Sage Foundation, 1992), pp. 31-126.
6 Down and Out in America, p. 34; Over the Edge, p. 123.
7 These programs included the Emergency Food and Shelter Program (P.L. 98-8), the Emergency Shelter Grants
Program (P.L. 99-591), and the Transitional Housing Demonstration Program (P.L. 99-591). In 1987, all three were
incorporated into the Stewart B. McKinney Homeless Assistance Act (P.L. 100-77), although the Transitional Housing
Demonstration Program was renamed the Supportive Housing Demonstration Program.
8 For information about other programs created by the McKinney Act, see CRS Report RL30442, Homelessness:
Targeted Federal Programs and Recent Legislation, coordinated by Libby Perl.
Congressional Research Service
1
.
The HUD Homeless Assistance Grants: Distribution of Funds
Among the programs authorized in the McKinney Act were four grants to provide housing and
related assistance to homeless persons: the Emergency Shelter Grants (ESG) program, the
Supportive Housing Demonstration program, the Supplemental Assistance for Facilities to Assist
the Homeless (SAFAH) program, and the Section 8 Moderate Rehabilitation Assistance for
Single Room Occupancy Dwellings (SRO) program. These four programs, administered by the
U.S. Department of Housing and Urban Development (HUD), were created to provide temporary
and permanent housing to homeless persons, along with supportive services. Over the years,
Congress has changed the makeup of the Homeless Assistance Grants, but there are still four
currently-funded programs, three of which were part of the original McKinney Act. The four
existing grants are the ESG program, the Supportive Housing Program (SHP), the Shelter Plus
Care (S+C) program, and the SRO program.
On May 20, 2009, for the first time since 1992, the Homeless Assistance Grants were
reauthorized as part of the Helping Families Save Their Homes Act (P.L. 111-22). The new law is
often referred to as the “HEARTH Act” after its title in P.L. 111-22 (the Homeless Emergency
Assistance and Rapid Transition to Housing Act). The HEARTH Act will change the makeup of
the four existing grants—the SHP, S+C, and SRO programs will be combined into one grant
called the “Continuum of Care Program;” the ESG program will be renamed the “Emergency
Solutions Grants;” and rural communities will have the option of competing for funds under a
new Rural Housing Stability Assistance Program. The way in which the funds are distributed, the
purposes for which grantees may use funds, and the people who may be served will also change.
The changes in the HEARTH Act technically became effective as of November 20, 2010 (the law
specified that provisions would take effect at the earlier of 18 months after enactment or three
months from the date on which HUD publishes final regulations). However, HUD has not issued
regulations, and has stated that until new regulations become effective, the current regulations
governing the Homeless Assistance Grants continue in place. As a result, this report continues to
describe how HUD currently distributes the four existing Homeless Assistance Grants. In
addition, citations to U.S. Code sections reflect the code as it existed prior to enactment of P.L.
111-22. For more information about the changes in P.L. 111-22, see the section of this report
entitled “Reauthorization of the McKinney-Vento Homeless Assistance Grants.”
The Role of Congress and HUD in the
Funding Process
Since creating the four Homeless Assistance Grants in 1987, Congress has played a decreasing
role in how funds are allocated among them. Initially, from FY1987 to FY1994, Congress
appropriated funds separately for each of the four programs. However, beginning in FY1995 and
continuing through FY2010, Congress appropriated one lump sum for all four programs, and
HUD has then determined how those funds are distributed among the ESG, SHP, S+C, and SRO
programs. However, in the FY2011 appropriations act Congress specified that at least $225
million be set aside for ESG. (For a distribution of the grants from FY1987 through FY2011, see
Table 1.)9
9 In addition to funds for the four grant programs, the congressional appropriation has also at times contained funds for
items like training and technical assistance, data collection, and the Interagency Council on Homelessness. These
amounts make up a small percentage of the total appropriation.
Congressional Research Service
2
.
The HUD Homeless Assistance Grants: Distribution of Funds
Typically, after Congress makes its annual appropriation for the Homeless Assistance Grants (this
amount was approximately $1.9 billion in FY2011—P.L. 112-1010), HUD has first allocated a
portion of the total appropriation to the ESG program. This amount has been between about 9%
and 15% of the total appropriation; HUD based this range of funding on the proportion of funds
Congress devoted to the program in its FY1994 appropriation. In FY2011, the set-aside specified
by Congress ($225 million) is approximately 12% of the total.
After HUD has set aside the ESG funds from the appropriation, it sets aside funds to renew S+C
permanent housing contracts in a separate account.11 In every HUD appropriations act since
FY2001, Congress has required HUD to provide funds to renew existing S+C contracts on an
annual basis, as long as HUD determines that the S+C projects are needed and meet program
requirements. The amount remaining after the ESG funds and S+C renewal funds are deducted
from the total appropriation is then available for the SHP and SRO programs, and for new S+C
projects. These remaining funds are not specifically dedicated to any of the three programs.
HUD uses two methods to distribute the funds to grantees—one for the ESG program and another
for the three remaining programs. HUD awards the funds allocated to the ESG program through a
formula allocation, and the SHP, S+C, and SRO program funds through a competitive application
system. For this reason, the SHP, S+C, and SRO programs are sometimes called the
“competitive” Homeless Assistance Grants.
Table 1. Funding for Homeless Assistance Grants,
FY1987-FY2011
($ in thousands)
Formula Grant
Competitive Grants
Emergency
Supportive
Total Funds for
Shelter
Single Room
Shelter Plus
Housing
HUD Homeless
Grants
Occupancy
Carea
Programb
Programs
(ESG)
(SRO)
(S+C)
(SHP)
(see note)
Fiscal Year
(a)
(b)
(c)
(d)
(e)
1987 60,000 35,000
— 59,000 195,000c
1988 8,000 — —
65,000 72,000
1989 46,500 45,000
— 80,000 171,500
1990 73,164 73,185
—
126,825 284,004d
1991 73,164 104,999
—
149,988 339,414e
1992 73,164 105,000
110,533
150,000 449,960f
1993 49,496 105,000
266,550
150,443 571,489
1994 113,840 150,000 123,747 334,000g 822,747h
1995 155,218 136,000 164,000 630,000
1,120,000i
10 The FY2011 appropriations law specifies that all discretionary programs are subject to an across-the-board rescission
of 0.2%.
11 Department of Housing and Urban Development, “Notice of Funding Availability (NOFA) for the Continuum of
Care Homeless Assistance Program,” September 14, 2010, p. 24, http://www.hudhre.info/documents/
FY2010CoCNOFA.pdf (hereinafter, FY2010 NOFA).
Congressional Research Service
3
.
The HUD Homeless Assistance Grants: Distribution of Funds
Formula Grant
Competitive Grants
Emergency
Supportive
Total Funds for
Shelter
Single Room
Shelter Plus
Housing
HUD Homeless
Grants
Occupancy
Carea
Programb
Programs
(ESG)
(SRO)
(S+C)
(SHP)
(see note)
Fiscal Year
(a)
(b)
(c)
(d)
(e)
1996 113,841 48,000 89,000 606,000 823,000
1997 113,727 24,000 61,000 663,000 823,000
1998 164,993 10,000 117,000 596,000 823,000
1999 150,000 17,000 151,000 556,000 975,000
2000 150,000 20,000 95,000 784,000 1,020,000
2001 149,670 14,000 174,000 760,000 1,122,525
2002 150,000 10,400 178,700 788,200 1,122,525
2003 149,025 11,200 237,000 865,400 1,217,037
2004 159,056 12,900 322,800 906,900 1,259,525
2005 158,720 14,900 304,400 860,900 1,229,214
2006 158,400 1,600 363,000 942,200 1,326,600
2007 160,000 1,611 383,000 942,900 1,434,403
2008 160,000 2,400 405,900
1,008,000 1,541,081
2009 160,000
0 487,900
1,069,700 1,677,000
2010 160,000 2,395 521,358
1,104,120 1,865,000
2011 224,550j — — —
1,901,190j
Sources: The FY2011 Department of Defense and Full-Year Continuing Appropriations Act (P.L. 112-10,
FY2011 funding levels), HUD Congressional Budget Justifications FY1988-FY2012 (al grants through FY1994,
competitive grants from FY2002 to FY2006 and FY2008 to FY2009, and total funds for HUD homeless
programs), HUD Homelessness Resource Exchange Continuum of Care Awards by Program Component
(FY2007 competitive grants), HUD Community Planning and Development grantee list FY1993-FY2010 (ESG
from FY1993 through FY2010), HUD’s Office of Special Needs (competitive grants for FY1987 and from FY1995
through FY2001), and CRS analysis of HUD funding announcements (competitive grants for FY2010).
Note: Until FY1995, Congress separately appropriated funds for each of the four Homeless Assistance Grants.
Since then, however, Congress has appropriated one amount for al four grants and HUD has divided the funds.
Therefore, amounts in columns (a) through (d) in the years FY1987 through FY1994 represent appropriations,
and those from FY1995 forward represent funds distributed to grantees. The amounts for each of the four
separate grant programs may add up to more or less than the amount in column (e) “Total for HUD Homeless
Programs,” which is the amount appropriated for HUD homeless program activities in a given fiscal year. In
some years, this could be due to the use of carryover funds, and in others, the sum of the four separate grants
may add up to less than the total due to al ocations to other funds like technical assistance, data col ection, or
the Interagency Council on Homelessness.
a. The S+C program was authorized in 1990 by P.L. 101-645 and first received funding in FY1992.
b. From FY1987 to FY1993, SHP was a demonstration program. In FY1987, it was cal ed the Transitional
Housing Demonstration Program (P.L. 99-591). SHP as it currently exists was authorized in P.L. 102-550.
c. The total includes $15 million for the Supplemental Assistance for Facilities to Assist the Homeless
(SAFAH) program. In 1992, P.L. 102-550 incorporated elements of SAFAH and the Supportive Housing
Demonstration Program into the new Supportive Housing Program.
d. The total includes $10,830,000 for the SAFAH program.
e. The total includes $11,263,000 for the SAFAH program.
Congressional Research Service
4
.
The HUD Homeless Assistance Grants: Distribution of Funds
f.
The total includes $11,263,000 for the SAFAH program.
g. In P.L. 103-124, Congress provided that of the amount appropriated for SHP, an amount not to exceed $50
million could be used for the Safe Havens Demonstration Initiative and $20 million for the Rural Housing
Demonstration Program.
h. The total includes $100 million for the Innovative Homeless Initiatives Demonstration Program.
i.
The total includes $25 million for the Innovative Homeless Initiatives Demonstration Program.
j.
The FY2011 Department of Defense and Full-Year Continuing Appropriations Act (P.L. 112-10) included an
across-the-board rescission of 0.2% for al discretionary programs that is reflected in the totals.
The Emergency Shelter Grants Program (ESG)
The ESG program, the oldest of the four existing Homeless Assistance Grants, was established
one year prior to enactment of McKinney-Vento as part of the Continuing Appropriations Act for
FY1987 (P.L. 99-591).12 The funds distributed through the ESG program provide for the
emergency shelter and service needs of homeless persons. The program uses the Community
Development Block Grant (CDBG) program dual formula to distribute funds to both local
communities (called “entitlement areas” and defined as metropolitan cities and urban counties13)
and states (called “non-entitlement areas”) for distribution in communities that do not receive
funds directly.14 Puerto Rico is considered a state under the CDBG formula and the District of
Columbia is an entitlement community. The territories (Guam, the Northern Mariana Islands, the
Virgin Islands, and American Samoa) receive 0.2% of the ESG allocation which is then
distributed based on population.15 Tribes do not receive funds through ESG; instead, funds for
homeless assistance are distributed through the Indian Community Development Block Grant.16
The CDBG program formula is meant to distribute funds based on a community’s need for
development; the ESG program has used the CDBG formula to target funds for homeless
assistance since its inception.17 The formula awards funds to metropolitan cities and urban
counties (70% of funds) and to the states for use in areas that do not receive funds directly (30%
of funds).18 The CDBG formula uses a combination of five factors to award funds to recipient
communities. (The CDBG formula uses four separate methods to award funds; this paper does
not discuss the details of these methods.) The five factors are population, the number of persons
in poverty, housing overcrowding (homes in which there are more than 1.01 persons per room),
the age of housing (the number of housing structures built prior to 1940), and the extent of growth
lag in a given community (the lack of population growth in a community compared to the growth
12 The ESG program was initially part of H.R. 5313, which was incorporated into H.Rept. 99-1005, the Conference
Report to accompany H.J.Res. 738, which became P.L. 99-591.
13 See 42 U.S.C. 11373(a), which refers to the statute governing the Community Development Block Grant at 42
U.S.C. §§ 5302(a)(4)-(6). A metropolitan city is the central city within a metropolitan statistical area, or a city of
50,000 or more within a metropolitan statistical area, and an urban county is a county within a metropolitan area that
has a population of 200,000 or more, or 100,000 or more if the county contains no incorporated areas.
14 For more information about CDBG, see CRS Report R41754, Community Development Block Grants: Funding
Issues in the 112th Congress and Recent Funding History, by Eugene Boyd.
15 24 C.F.R. § 576.5(a).
16 U.S. Department of Housing and Urban Development, Emergency Shelter Grants Program FY2008 Operating
Instructions, October 2008, p. 2, http://www.hudhre.info/documents/ESG_OperatingInstructions_2008.pdf.
17 For a description of the factors used in the CDBG formula, see the section of this report entitled, “The Role of the
Community Development Block Grant Formula.”
18 42 U.S.C. §§ 5306(a) - (d).
Congressional Research Service
5
.
The HUD Homeless Assistance Grants: Distribution of Funds
rate it would have had if it had grown at the rate of other communities).19 The factors are
measured as ratios between the recipient community and all grant recipients. The CDBG formula
was last changed in 1977 (P.L. 95-128).
After the CDBG formula determines the amount of ESG funds each state and community
receives, they, in turn, allocate the funds to local government entities and nonprofit organizations
that provide services for homeless persons. These recipient organizations may use funds for four
main purposes: the renovation, major rehabilitation or conversion of buildings into emergency
shelters; services such as employment counseling, health care, and education; homelessness
prevention activities such as assistance with rent or utility payments; and operational and
administrative expenses.20 States and communities must ensure that not more than 30% of the
total ESG funds they receive is used for services, not more than 30% is used for homelessness
prevention activities, not more than 10% is used for staff costs, and not more than 5% is used for
administrative costs.21
Distribution of ESG Funds
As a condition for receiving ESG funds, states and communities must present HUD with a
consolidated plan explaining how they will address community development needs within their
jurisdictions. The consolidated plan is required in order for communities to participate in four
different HUD grant programs, including ESG.22 The plan is a community’s description of how it
hopes to integrate decent housing, community needs, and economic needs of low- and moderate-
income residents over a three- to five-year time span.23 Consolidated plans are intended to be
collaborative efforts of local government officials, representatives of for-profit and non-profit
organizations, and community members. HUD may disapprove a community’s consolidated plan
with respect to one or more programs, although communities have 45 days to change their plans
to satisfy HUD’s requirements.24 If HUD disapproves the ESG portion of the plan, the applicant
community will not receive ESG funds.
If HUD approves a community’s consolidated plan, the community will receive ESG funds based
on its share of CDBG funds from the previous fiscal year. However, the community must have
received at least 0.05% of the total CDBG allocation in order to qualify to receive ESG funds.25
In cases where a community would receive less than .05% of the total ESG allocation, its share of
funds goes to the state to be used in areas that do not receive their own ESG funds.26 For example,
if a community received 0.08% of the total CDBG allocation to the states in FY2000, it would
receive that same percentage of ESG funds in FY2001. In FY2011, an estimated 360 states, cities,
19 42 U.S.C. § 5306.
20 42 U.S.C. § 11374(a).
21 Ibid.
22 The other programs are the Community Development Block Grant program, the HOME program, and the Housing
Opportunities for Persons with AIDS (HOPWA) program. For more information about HOME, see CRS Report
R40118, An Overview of the HOME Investment Partnerships Program, by Katie Jones, and for more information about
HOPWA, see CRS Report RL34318, Housing for Persons Living with HIV/AIDS, by Libby Perl.
23 24 C.F.R. § 91.1(a).
24 24 C.F.R. § 91.500.
25 42 U.S.C. § 11373.
26 42 U.S.C. § 11373(b).
Congressional Research Service
6
.
The HUD Homeless Assistance Grants: Distribution of Funds
counties, and territories will receive ESG funds.27 The $225 million that Congress stipulated be
set aside for ESG represented approximately 12% of the total amount appropriated for the
Homeless Assistance Grants.
After the recipient states and entitlement communities receive their ESG funds, they distribute
them to local government entities or nonprofit organizations that provide services to homeless
persons. These recipient organizations have been previously determined by the state or local
government through an application process in which organizations submit proposals—HUD is
not involved in this process. Each recipient organization must match the federal ESG funds dollar
for dollar.28 The match may be met through the value of donated buildings, the lease value of
buildings, salary paid to staff, and volunteer time counted at $5 an hour.29
The Three Competitive Homeless Assistance Grants
The bulk of the funding for the Homeless Assistance Grants is awarded to the three competitive
grant programs: the SHP, S+C, and SRO programs. In FY2010, more than 90% of the total
amount of funds appropriated for the four grant programs went to the competitive grants. The
composition of the homeless programs that are part of the competitive grant process has remained
relatively stable since the passage of McKinney-Vento in 1987. The three existing programs have
together comprised the competitive grants since FY1992. Both the SHP and the SRO program
were part of the original McKinney Act in 1987, and the S+C program was added in 1990 (P.L.
101-645). Congress later made two other programs, the Safe Havens for Homeless Individuals
Demonstration Program and the Rural Homeless Housing Assistance Program (both enacted in
P.L. 102-550), part of McKinney-Vento, and gave HUD authority to allocate funds to them from
the SHP appropriation. While Safe Havens have been an eligible use of SHP dollars ever since,
the Rural title of McKinney-Vento was never funded.
The three competitive Homeless Assistance Grants each perform somewhat different functions,
but all three have a unified focus in that they concentrate on the longer-term needs of homeless
individuals and families rather than their emergency requirements. These longer-term needs
include transitional housing (up to 24 months), permanent housing, and supportive services.
Supportive services are designed to help homeless individuals with a variety of issues that might
prevent them from being able to find and maintain permanent housing (for example, employment
counseling, health care, and child care). Differences among the programs occur in the eligible
uses of funds, the way in which housing to homeless persons is provided, match requirements by
grant recipients, and the eligible populations served. (For a breakdown of some of these
distinctions, see Table 2.)
The Supportive Housing Program (SHP)
The SHP provides funds for transitional housing for homeless individuals and families for up to
24 months, permanent housing for homeless individuals with disabilities, and supportive
27 HUD Office of Community Development, http://www.hud.gov/offices/cpd/about/budget/budget11/index.cfm.
28 42 U.S.C. § 11375(a).
29 Ibid.
Congressional Research Service
7
.
The HUD Homeless Assistance Grants: Distribution of Funds
services.30 In FY2010, approximately 68% of total HUD competitive grant funds went to
recipients as SHP grants.31 Eligible applicants for SHP grants include states, local government
entities, public housing authorities (PHAs), private nonprofit organizations, and community
mental health centers.32 Grant recipients can provide housing together with services, or can
choose to provide services only (without a housing program component). Specifically, funds may
be used to acquire and/or rehabilitate buildings that will be used either to provide supportive
housing or buildings that will be used to provide supportive services only. Funds may also be
used to construct buildings that will be used for supportive housing (but not supportive services
only).33
In addition to financing physical structures, grantees may use funds to provide services like case
management, health care, child care, housing assistance, nutritional counseling, and employment
assistance. Grant recipients may provide these services themselves, or through contracts with
outside providers. In addition, grant recipients may use funds to pay for up to 75% of their annual
operating expenses and to help implement a Homeless Management Information System (HMIS)
to keep records regarding the homeless individuals served within their community.
Recipients of SHP grants are required to meet match requirements. All of the matching funds
must be provided by cash sources,34 but the level of non-federal funds required varies with the
type of activity undertaken. Funds that are to be used for acquisition, rehabilitation, or new
construction must be matched with an equal amount of the grant recipient’s own funds.35 Those
SHP grantees that receive funds for supportive services must provide at least a 20% match with
funds from other sources, while grantees that receive funds for operating expenses must provide
at least a 25% match of these funds on their own.36
The Single Room Occupancy Program (SRO)
The Single Room Occupancy (SRO) program provides permanent housing to homeless
individuals in efficiency units similar to dormitories, with single bedrooms, community
bathrooms, and kitchen facilities. In FY2010, two new competitive grants were awarded to SRO
projects for a total of approximately $2.4 million.37 The SRO program does not require homeless
residents to have a disability and does not fund supportive services. Eligible applicants for SRO
grants are PHAs and private nonprofit organizations.38 SRO units are funded as part of HUD’s
Section 8 Moderate Rehabilitation program, which requires grant recipients to spend at least
$3,000 per unit to rehabilitate property to be used for SRO housing in order to bring the property
30 At least 10% of total SHP funds must be used for supportive services, at least 25% must be used for projects that
serve families with children, and at least 25% must be used for projects that serve homeless persons with disabilities.
42 U.S.C. § 11389(b).
31 CRS analysis of HUD grant announcements, available at http://portal.hud.gov/hudportal/documents/huddoc?id=
press_report2010.pdf, and http://www.hud.gov/offices/cpd/homeless/budget/2010/10_all_grants.pdf.
32 42 U.S.C. § 11382(1).
33 42 U.S.C. § 11383.
34 24 C.F.R. § 583.145.
35 42 U.S.C. § 11386(e).
36 FY2010 NOFA, p. 10.
37 U.S. Department of Housing and Urban Development, FY2010 Continuum of Care Competition Homeless Assistance
New Project Awards, April 28, 2011, http://portal.hud.gov/hudportal/documents/huddoc?id=press_report2010.pdf.
38 42 U.S.C. § 11401(j).
Congressional Research Service
8
.
The HUD Homeless Assistance Grants: Distribution of Funds
into compliance with HUD’s housing quality standards.39 Grant recipients are reimbursed for the
costs of rehabilitating SRO units through Section 8 rental assistance payments that they receive
over a ten-year contract period. The costs of rehabilitation are amortized and added to a base
rental amount. The maximum amount that a building owner can spend per unit and still be
reimbursed is $22,500 as of FY2010 (this amount is updated annually).40 After the 10-year rental
contracts expire, they are not renewed through the Homeless Assistance Grant competition, but
through the Section 8 project-based rental assistance account on an annual basis.41
The Shelter Plus Care Program (S+C)
The S+C program provides permanent supportive housing through rent subsidies for homeless
individuals with disabilities and their families. In FY2010, approximately 32% of total
competitive grant funds went to S+C grantees.42 Eligible applicants for the S+C grants are states,
local government entities, and PHAs.43 The S+C rent subsidies may be tenant-based vouchers,
project-based rental assistance, sponsor-based rental assistance, or single room occupancy
housing.44 With tenant-based vouchers, residents find private market housing much as they would
with a Section 8 voucher; project-based assistance is provided to building owners and attached to
specific units of housing (unlike a portable voucher); with sponsor-based assistance, grant
recipients contract with private nonprofit housing providers or community mental health centers
to provide housing; and rental assistance for SROs is targeted to a particular development.45 The
S+C program requires grant recipients to match the amount of grant funds they receive for rental
assistance with an equal amount of funds that they will use to provide supportive services.46 The
services under S+C are similar to those provided in the SHP, and include activities like physical
and mental health care, substance abuse counseling, child care services, case management, and
educational and job training.47 Grant recipients can fulfill their match requirement with cash, the
value of a lease, salary expenses for employees, or the time of volunteers.
Resident Contributions to Housing Costs
In the SHP, S+C, and SRO programs, residents are asked to pay a portion of their income toward rent, if they are
able. In all three programs, rent may not exceed the greater of 30% of adjusted income, 10% of gross income, or if a
family receives welfare benefits, the portion of the benefit designated for housing costs.
39 24 C.F.R. § 882.802.
40 See FY2010 NOFA, p. 25.
41 Ibid.
42 CRS analysis of HUD grant awards. See footnote 31 for sources.
43 42 U.S.C. § 11403g(2).
44 42 U.S.C. §§ 11404-11406b.
45 U.S. Department of Housing and Urban Development, Shelter Plus Care Resource Manual, Section 1.2,
http://www.hudhre.info/index.cfm?do=viewSpcResourceMan.
46 42 U.S.C. § 11403b(a).
47 24 C.F.R. § 582.5.
Congressional Research Service
9
.
The HUD Homeless Assistance Grants: Distribution of Funds
Table 2. Characteristics of the SHP, S+C, and SRO Programs
Supportive
Housing
Single Room
Program
Program
Shelter Plus Care
Occupancy
Characteristics
(SHP)
(S+C)
(SRO)
Eligible Uses of Funds
-Transitional
Housing
-Permanent Housing
-Permanent Housing
-Permanent
Housing
-Supportive
Services
-Operating
Expenses
Eligible Applicants
-States
-States
-PHAs
-Local
Government
-Local
Government
-Private Nonprofits
Entities
Entities
-PHAs
-PHAs
-Private
Nonprofits
-Community
Mental
Health Centers
Eligible Populations
-Families and individuals
-Individuals with
-Individuals
(transitional housing and
disabilities and their
services only)
families
-Individuals
with
disabilities
Match Requirements
-Dollar for Dollar
-Equal amount of funds
-No match requirement
(acquisition,
for services
rehabilitation, or
construction)
-20%
(services)
-25%
(operating
expenses)
FY2010 Percentage of
Competitive Funds
67.83%
32.03%
0.15%
Source: The McKinney-Vento Homeless Assistance Act, Title IV, Subtitles C, E, and F, 42 U.S.C. §§ 11381-
11389, 11401, and 11403-11407b, and CRS analysis of FY2010 HUD Homeless Assistance Grant al ocations.
Distribution of the Competitive Grants and the
Continuum of Care (CoC) Process
The three competitive grants are distributed to eligible applicant organizations through a
complex, multi-step process that involves both formula and competitive elements. HUD first uses
the CDBG formula to determine the need levels of local communities (generally, a combination
of cities and counties); the need level is effectively the maximum amount of funding that a given
community can receive. HUD then determines through a competition whether applicant
organizations that provide services to homeless persons qualify for funds. In the early years that
the Homeless Assistance Grants existed, individual homeless services providers applied to HUD
directly for funds. However, since FY1996 HUD has required applicants to participate in a
collaborative community process called the Continuum of Care (CoC) application system if they
Congressional Research Service
10
.
The HUD Homeless Assistance Grants: Distribution of Funds
want to receive SHP, S+C, or SRO funds. For an overview of how funds are distributed, see
Figure 1, at the end of this section.
The Continuum of Care
HUD developed the CoC as both a way for communities to plan services that will address the
needs of homeless persons, and the method through which service providers apply for HUD
funds.48 Under the CoC strategy, local communities establish CoC advisory boards made up of
representatives from local government agencies, service providers, and community members who
meet to establish local priorities and strategies to address homelessness in their communities. The
CoC plan that results from this process is meant to contain elements that address the continuum of
needs of homeless persons: prevention of homelessness, emergency shelter, transitional housing,
permanent housing, and supportive services provided at all stages of housing.49 The CoC system
was created in 1993 as the Innovative Homeless Initiatives Demonstration Program, a grant
program that provided funding to communities so that they could become more cohesive in their
approach to serving homeless people.50 Since then, nearly every community in the country has
become part of a CoC, with approximately 452 CoCs in existence as of 2010, including those in
the territories.51
Since the FY1996 grant application process for the competitive Homeless Assistance Grants, the
CoC system has also been the vehicle through which local service providers apply for HUD
competitive grants.52 The process of applying for the competitive Homeless Assistance Grants
begins at the local level when individual applicant organizations apply to their CoC advisory
boards to be included in a unified CoC application to HUD for funding. Continuums have
flexibility in how they set up their application processes, called the “review and ranking” process,
and may have written guidelines available for applicants. HUD requires that the process be fair,
and CoCs must explain in their grant applications to HUD the methods they use to ensure
fairness, together with a list of any complaints they received from applicant organizations.53
Applicant organizations may also address fairness and other concerns directly to HUD.
Each CoC selects the homeless assistance projects that it thinks should be funded and prioritizes
them in a list that is included in an overall CoC application to HUD. The CoC application packet
accompanying the list has multiple parts. It includes an overall CoC application with information
about the CoC structure and assessment of community needs, and individual applications for each
listed project that the CoC recommends for funding. Continuums send the entire application
48 The development of the Continuum of Care system is described in Priority: Home! The Federal Plan to Break the
Cycle of Homelessness, The U.S. Department of Housing and Urban Development, 1994, pp. 73-75.
49 Barnard-Columbia Center for Urban Policy, The Continuum of Care: A Report on the New Federal Policy to Address
Homelessness, U.S. Department of Housing and Urban Development, December 1996, p. 9.
50 See U.S. Department of Housing and Urban Development, “Funding Availability for Fiscal Year 1994 for Innovative
Project Funding Under the Innovative Homeless Initiatives Demonstration Program,” Federal Register vol. 58, no. 243,
December 21, 1993, pp. 67616-67618.
51 “HUD-Defined CoC Names and Numbers Listed by State,” Revised April 2010, http://www.hudhre.info/documents/
2010ListingCoCs.pdf.
52 U.S. Department of Housing and Urban Development, “Continuum of Care Homeless Assistance; Funding
Availability,” Federal Register vol. 61, no. 52, March 15, 1996, pp. 10865-10877.
53 Exhibit I of Continuum of Care application, http://www.hud.gov/offices/adm/hudclips/forms/files/40090-1.doc. This
document is from the 2007 application. Since FY2008, HUD has used an online application system, and application
materials are not available.
Congressional Research Service
11
.
The HUD Homeless Assistance Grants: Distribution of Funds
packet to HUD, which in turn determines the projects that will be funded, and how much funding
each will receive. Note that HUD determines funding at the individual project level, not the CoC
level, although HUD considers factors involving the CoC in making its decisions.
HUD Determination of CoC Pro Rata Need
Before the CoC applications even arrive at HUD, the agency goes through a process where it
calculates each community’s “pro rata need.” Pro rata need is meant to represent the dollar
amount that each community (city, county, or combination of both) needs in order to address
homelessness. HUD determines a pro rata need amount for each community and then adds
together the individual need amounts of the communities within a CoC to arrive at a pro rata need
amount for the entire Continuum. This CoC pro rata need amount is essentially the maximum
amount of HUD Homeless Assistance Grant funds for which a CoC can qualify. Pro rata need
does not include amounts needed to renew S+C contracts or amounts for a Permanent Housing
Bonus (described later in this section). CoCs qualify for either a “preliminary pro rata need”
(PPRN) level or a “hold harmless need” (HHN) level, described below.
Preliminary Pro Rata Need
To calculate preliminary pro rata need, HUD takes the proportion of funds each community is
entitled to under the ESG program (which uses the CDBG formula), and multiplies this
proportion by the total amount of competitive funds available to grantees (after subtracting the
amount needed for S+C renewals) to arrive at a dollar amount of preliminary pro rata need. For
example, if a city is eligible for 0.08% of total ESG funds, and $1.1 billion is available for the
competitive Homeless Assistance Grants in a given year, the dollar amount of preliminary pro
rata need assigned to that community is $960,000. The preliminary pro rata need amount for each
city and county within a CoC is then added together to arrive at a total preliminary pro rata need
amount for the CoC.
Hold Harmless Pro Rata Need
HUD applies a hold harmless level of need in cases where the total cost of a CoC’s one-year
renewal of SHP contracts exceeds the preliminary pro rata need amount. In these cases, an
amount equal to the difference between preliminary pro rata need and the cost of SHP renewals is
added to preliminary pro rata need to bring the CoC up to a hold harmless level (effectively this
means that the cost of SHP one-year renewals is the hold harmless level). For example, a
Continuum’s total cost of renewing SHP contracts is $4 million, but the preliminary pro rata need
is only calculated to be $2.3 million. The difference between these two amounts ($1.7 million) is
added to preliminary pro rata need ($2.3 million) to arrive at the hold harmless need level of $4
million.
Beginning with the FY2005 grant competition, HUD allowed CoCs to reallocate their hold
harmless need from existing SHP projects to new projects under any of the three competitive
grants. In the FY2008 competition, CoCs could also choose to reallocate SHP renewal funds to an
HMIS project. HUD did not allow CoCs to reallocate hold-harmless need in FY2009, but
Congressional Research Service
12
.
The HUD Homeless Assistance Grants: Distribution of Funds
resumed the reallocation policy for FY2010, allowing funds to go to permanent housing projects
or HMIS.54
Final Pro Rata Need
Final pro rata need (FPRN) is the higher of PPRN or HHN. Whether the CoC is in PPRN status or
HHN status, in order to receive sufficient funding for existing projects that must be renewed, the
CoC must prioritize those renewal projects within the final pro rata need level, or they will not
receive sufficient funding.
In the FY2010 competition for funds, HUD encouraged CoCs to merge in cases where the
resulting geographic entity would be able to operate more efficiently and effectively than the
individual CoCs. According to HUD, this may particularly be the case for smaller CoCs that
merge with larger ones.55 However, in order to merge, at least one CoC has to be in PPRN status
and one has to be in HHN status. The FPRN for merging CoCs is the sum of the FPRNs for each
individual CoC (the higher of PPRN or HHN).
Permanent Housing Bonus (Previously the Samaritan Housing Initiative)
The Permanent Housing Bonus, formerly called the Samaritan Housing Initiative or Samaritan
Bonus, consists of funds appropriated through the competitive Homeless Assistance Grants that
HUD has set aside for grantees to develop permanent supportive housing for homeless
individuals. The way in which the funds can be used has evolved over the years. For the first few
years after HUD created the Samaritan Initiative or Bonus (from FY2005 through FY2007), funds
were awarded as part of the CoC competition, with the bonus computed as part of the pro rata
need process. FY2008 was the first year in which funds for the Samaritan Bonus were awarded
separately. In FY2009, the Samaritan Bonus was renamed the Permanent Housing Bonus, and the
way in which CoCs can use funds was expanded. The bonus is available again in FY2010.
Under the Samaritan Bonus, CoCs had to use funds to create new permanent supportive housing
for chronically homeless individuals. Until enactment of the HEARTH Act, a chronically
homeless person was defined as an individual with a disabling condition who had been
continuously homeless for one year or has had four episodes of homelessness in the last three
years.56 Initially, CoCs could not create more than one project with Samaritan Bonus funds, but in
FY2008 CoCs could propose and receive funding for one or more projects. In the FY2009 and
FY2010 competitions, HUD expanded the populations that CoCs could serve—grantees can now
create permanent supportive housing for individuals with disabilities or families with an adult
member who has a disability.
A CoC may qualify for additional funds under the Permanent Housing Bonus up to a maximum of
15% of its preliminary pro rata need or $6 million, whichever is lower. For example, if a
Continuum has a preliminary pro rata need of $2 million with a hold-harmless level that brings its
54 FY2010 NOFA, pp. 8.
55 Ibid., pp. 13-14.
56 24 C.F.R. § 91.5. The HEARTH Act amended the definition to include homeless families with an adult head of
household who has a disability.
Congressional Research Service
13
.
The HUD Homeless Assistance Grants: Distribution of Funds
need level up to $3 million, it may receive a Permanent Housing Bonus of $300,000 (15% of $2
million).57
Renewal of SHP and S+C Projects
As mentioned earlier in this report, renewals of S+C contracts take place outside of the CoC
competition due to language in appropriations acts that require renewal as long as a given project
is “determined to be needed” and meets financial and program standards.58 However, until
FY2009 SHP renewals had been made as part of the competitive process. But beginning in
FY2009 and continuing in FY2010, HUD also renewed previously funded SHP contracts
(including HMIS) that were set to expire in 2011 for one year outside of the competitive
process.59 In order to be renewed, projects had to meet certain threshold requirements including
performance, timeliness in expenditure of previously awarded funds, and assistance to program
participants.60 As a result, the FY2009 and FY2010 competitive processes, described in the next
section, have consisted of proposals for new projects only.
The Competition for New Project Funding
Threshold Review
When CoC applications arrive at HUD, the agency first goes through a threshold review of the
individual project applications within each CoC application. In this process, HUD looks at
various eligibility factors to ensure that every participant in the proposed projects (from applicant
organizations to clients who will be served) is eligible for the Homeless Assistance Grants for
which they are applying. The following list is illustrative of the factors that HUD considers, and
does not include every element that HUD reviews.61
• HUD confirms that applicants are eligible to operate the program for which they
are seeking funds. For example, only PHAs and private nonprofit organizations
may operate an SRO project.
• The applications must demonstrate that the proposed projects are eligible for
funding, for example that the population to be served is eligible for assistance,
that the projects will be accessible to persons with disabilities, that they are cost
effective, and that the applicant organizations are participating (or will
participate) in any local Homeless Management Information System.
• HUD assesses the potential quality of proposed projects by ensuring that the type
of housing and its location fit the needs of participants, and that participants will
be assisted with a variety of services.
57 FY2010 NOFA, p. 11.
58 See the FY2010 Consolidated Appropriations Act, P.L. 111-117.
59 U.S. Department of Housing and Urban Development, “HUD Awards $1.4 Billion to Nearly 7,000 Local Homeless
Programs—Part of Administration Plan to Prevent & End Homelessness,” press release, January 19, 2011,
http://portal.hud.gov/hudportal/HUD?src=/press/press_releases_media_advisories/2011/HUDNo.11-005.
60 FY2010 NOFA, pp. 19-20.
61 For all of the eligibility factors, see FY2010 NOFA, pp. 18-19.
Congressional Research Service
14
.
The HUD Homeless Assistance Grants: Distribution of Funds
• In order to receive funding, projects must comply with civil rights and fair
housing requirements.
Scoring the Applications
In the final step, HUD reviews each individual project application and assigns points to each
project that the Continuums have recommended for funding. Until the FY2008 competition, HUD
awarded a total of 100 points in two categories: points for need (40 points) and for CoC factors
(60 points). Need was based on each individual project’s ranking within a CoC’s application,
while CoC factors were based on various characteristics and performance outcomes of CoCs.
However, in the FY2008 competition, HUD eliminated points for need; instead, need is
accounted for in the pro rata need determination process. The entire 100 points are now awarded
on the basis of CoC factors. Note that even though points are based on CoC applications, points
are awarded to individual projects within the CoC application. This means that each project
proposed by a given CoC receives the same score.
The points that are awarded to projects on the basis of CoC factors are used to determine which
projects will be funded. Projects that score above a certain point threshold will receive full
funding up to their final pro rata need. In cases of ties, HUD has established a tie-breaking
system.62 The threshold number of points needed to be funded varies from year to year. In
FY2010, HUD has established a scoring threshold of 65 points for new projects to be funded.63
Points for Continuum of Care Factors
The CoC factors that HUD scores may vary from year to year. In the most recent Notice of
Funding Availability, for FY2010, there were five categories in which projects were scored.64 The
categories were the same as those that HUD evaluated in FY2009. Below are descriptions of the
factors HUD will evaluate in the FY2010 competition, together with the point totals for each.
• CoC Housing, Services, and Structure: HUD awards points for the existence of
an inclusive and outcome-oriented community process to develop a CoC strategy,
and a fair and impartial project review and selection process. The strategy should
be comprehensive, addressing the continuum of services, and designed to serve
all homeless subpopulations. In addition, the CoC should have created,
maintained, and built upon housing and services available to meet the needs of
homeless persons. A total of 14 points is available in this category.
• Homeless Needs and Data Collection: This category awards points on the basis
of a CoC’s understanding of the number of homeless individuals in the CoC’s
area and their needs, as well as a CoC’s progress in implementing an HMIS to
compile information about clients served and provide an unduplicated count of
homeless persons. A total of 26 points is available in this category.
• CoC Strategic Planning: HUD awards points in this category to Continuums with
10-year plans to end chronic homelessness, and those with discharge policies for
62 Ibid., pp. 33-34.
63 Ibid., p. 33.
64 Ibid., pp. 28-31.
Congressional Research Service
15
.
The HUD Homeless Assistance Grants: Distribution of Funds
persons leaving institutional care (for example, correctional facilities, hospitals,
or foster care). HUD also considers whether CoCs are able to leverage funds
from other sources for new projects and the extent to which they coordinate with
other federal homeless programs in their area (such as the HUD-VA Supported
Housing Program (HUD-VASH) and the Homelessness Prevention and Rapid
Rehousing Program (HPRP)) as well as HUD projects funded through the
American Recovery and Reinvestment Act. A total of 22 points is available in
this category.
• CoC Performance: The factors considered in this category include steps that
CoCs have taken to meet their goals, whether CoCs have increased the number of
permanent housing beds for chronically homeless individuals, whether there has
been a decrease in chronic homelessness, the success that homeless individuals
have in remaining in permanent housing, the success of homeless individuals in
gaining access to available government programs and funds, and the
implementation of energy-efficiency measures in housing and community
facilities. A total of 32 points is available in this category.
• Emphasis on Housing Activities: Within this category, HUD awards points to
Continuums based on the percentage of funds to be used to provide housing
(versus services) in new projects only. CoCs need not use all funds for housing in
order to receive the maximum number of available points. A total of six points is
available in this category.
Funding Priorities
Notwithstanding the scoring system, HUD set out funding priorities for the FY2010 CoC funds,
including a set aside of $30 million to fund new housing projects in areas that are considered
100% rural. The priorities, including funding for rural areas, work as follows.
• As mentioned previously, HUD funds eligible S+C renewal projects, and then
funds renewals of eligible SHP projects.65
• Next, as directed by the appropriations law, HUD must reserve 30% of funds for
permanent housing for homeless persons (excluding the funds used for S+C
renewal projects). SHP renewals of permanent housing contracts count toward
the 30% threshold, but if they are insufficient, HUD will select (1) new
permanent housing projects that will serve 100% rural areas in order by total
points scored;66 (2) new permanent housing projects in CoCs generally, whether
in rural areas or not; and (3) Permanent Housing Bonus projects.
• Once the 30% threshold for permanent housing is met, HUD may decide to fund
HMIS projects even if they have lower point totals than other proposed projects.
• HUD will fund transitional housing and safe haven projects that propose to serve
100% rural areas.
• After the previous priorities are met, HUD will fund new CoC projects in order
by their CoC score.
65 Ibid., pp. 31-32.
66 The 2010 NOFA lists counties that qualify as 100% rural.
Congressional Research Service
16
.
The HUD Homeless Assistance Grants: Distribution of Funds
Allocation of the Grants
Despite the fact that Continuums of Care serve as intermediaries between HUD and individual
homeless service providers during the application process, funds go directly to service providers,
not to the CoC. Projects receive funding for between one and ten years depending on the type of
project and whether it is a new contract or a renewal. New SHP projects are funded for two or
three years, although renewals in FY2010 were funded for one year.67 Initial S+C contracts run
for five years or for 10 years if the projects are either SRO units or involve project-based rental
assistance where rehabilitation has occurred.68 S+C renewals are made for one year at a time.
SRO projects are funded for ten years (renewals take place outside the Homeless Assistance
Grant application process).69 Grant recipients enter into a grant agreement with HUD, and must
follow deadlines regarding construction and obligation of funds.70
Special Activities
In recent years, HUD has distributed funds to serve homeless individuals through programs that
are not directly part of the four Homeless Assistance Grants discussed in this report. Each of the
three programs—the Rapid Re-Housing Demonstration Program, the Homelessness Prevention
and Rapid Re-Housing Program, and targeted Section 8 vouchers—reflects different policy
priorities when it comes to serving homeless individuals.
The Rapid Re-Housing Demonstration, for which Congress appropriated funds in FY2008,
focused on finding housing for homeless families with children, a group sometimes thought to be
neglected in favor of serving chronically homeless individuals. The Homelessness Prevention and
Rapid Re-Housing Program (HPRP) expanded on the Rapid Re-Housing Demonstration,
allowing funds to be used to quickly find housing for those who are homeless while also
emphasizing the prevention of homelessness, something for which only a small portion of HUD
funds has been used in the past. To date, the third category of funding—targeted Section 8
vouchers—has been used to serve homeless veterans, but the President’s FY2011 and FY2012
budgets have also proposed funding new vouchers to address the needs of both chronically
homeless individuals and homeless families with children. The FY2011 Department of Defense
and Full-Year Continuing Appropriations Act (P.L. 112-10) did not include funding for the
proposed vouchers.
Rapid Re-Housing Demonstration Program
Rapid re-housing is a process targeted to assist homeless families with dependent children that
have one or more moderate barriers to achieving and maintaining permanent housing. Through
supportive services to address these barriers, together with short-term housing assistance, the
hope is that families will be able to maintain permanent housing. In the FY2008 Consolidated
Appropriations Act (P.L. 110-161), Congress appropriated $25 million for a Rapid Re-Housing
Demonstration Program. HUD awarded the funds through a competitive process to 23 projects
67 FY2010 NOFA, pp. 16-17.
68 Ibid.
69 Ibid.
70 Ibid, pp. 34-36.
Congressional Research Service
17
.
The HUD Homeless Assistance Grants: Distribution of Funds
proposed by Continuums of Care for funding. The announcement of grant award recipients was
made on February 19, 2009.71
Rapid Re-Housing grantees provide supportive services and transitional housing assistance to
help families move to permanent housing as quickly as possible. Under the Rapid Re-Housing
grant, service providers could fund transitional housing for one of two time periods, to be
determined by the service provider at the time it assesses the needs of a given family. These two
time periods were either 3-6 months or 12-15 months. Grantees could not use more than 30% of
funds for supportive services.72 Among the moderate barriers to achieving permanent housing that
families had to face in order to be eligible for Rapid Re-Housing services were (1) temporary
financial strain, (2) inadequate employment or loss of employment, (3) inadequate childcare
resources, (4) an ability to overcome a low level of education or command of the English
language, (5) legal problems that can be addressed by a service provider, (6) minimal mental
health issues or prior substance use, and (7) poor rental and credit history.73
The Homelessness Prevention and Rapid Re-Housing Program
Congress appropriated $1.5 billion for a new Homelessness Prevention and Rapid Re-Housing
Program (HPRP) as part of the American Recovery and Reinvestment Act (P.L. 111-5). The funds
were distributed to states and local communities using the ESG program formula to determine
allotments.74 Although funds were distributed via the ESG formula, unlike the ESG program,
where only 30% of funds could, at the time, be used for homelessness prevention activities, all
funds are to be used for activities to prevent homelessness or to quickly find housing for those
who have become homeless. In addition, because the amount of HPRP funds available greatly
exceeded typical ESG appropriations, more cities and counties qualified for the minimum HPRP
grant of $500,000; under HPRP, 337 cities qualified for their own grant (compared to 203 that
received FY2009 ESG allocations) and 148 urban counties qualified for their own HPRP grant
(compared to 102 that received funds under the FY2009 ESG grants). As with ESG, grantee state
and local governments may allocate funds to subgrantees that are agencies within government or
private nonprofit organizations. Unlike ESG, there are no match requirements for HPRP funds.
Grantees must expend at least 60% of funds within two years of the date that the funds were made
available by HUD, and 100% of funds within three years.75
On March 19, 2009, HUD released a notice in which it detailed requirements for grantees and
subgrantees.76 Recipients may use funds to assist individuals and families who find themselves in
two different sets of circumstances—those who, but for HPRP assistance, would become
71 U.S. Department of Housing and Urban Development, “Obama Administration Awards Nearly $1.6 Billion in
Homeless Grants to Thousands of Local Housing and Service Providers Nationwide,” press release, February 19, 2009,
http://portal.hud.gov/hudportal/HUD?src=/press/press_releases_media_advisories/2009/HUDNo.09-010.
72 Department of Housing and Urban Development, “Notice of Funding Availability, Continuum of Care Homeless
Assistance,” Federal Register, vol. 73, no. 133, July 10, 2008, p. 39843.
73 Ibid., p. 39846.
74 The list of HPRP recipients is available at http://www.hud.gov/recovery/homeless-prevention.cfm.
75 For a report on grantee expenditures, see http://www.hudhre.info/documents/
HPRP_FinancialReport60PctReq_byState.pdf.
76 U.S. Department of Housing and Urban Development, Notice of Allocations, Application Procedures, and
Requirements for Homelessness Prevention and Rapid Re-Housing Program Grantees under the American Recovery
and Reinvestment Act of 2009, March 19, 2009, http://www.hud.gov/recovery/hrp-notice.pdf.
Congressional Research Service
18
.
The HUD Homeless Assistance Grants: Distribution of Funds
homeless and those who currently meet HUD’s definition of homelessness.77 In both cases, those
assisted should only require temporary assistance in order to find and retain housing, and must
have incomes at or below 50% of area median income (considered very low income).78 Funds
may be used for short-term rental assistance (up to 3 months) or medium-term rental assistance
(4-18 months), for security or utility deposits, utility payments, help with moving expenses, and
hotel vouchers. Recipients may also use funds for activities to help families find and maintain
housing such as help with housing searches, outreach to landlords, credit repair, and legal
services. The notice explicitly states that funds may not be used for mortgage costs.79
In June 2011, HUD released data about how HPRP funds have been used as part of The 2010
Annual Homeless Assessment Report to Congress.80 In the first year of the program (from
implementation in September 2009 through September 2010), more than 690,000 people were
served, the majority of whom—approximately 77%—received assistance with homelessness
prevention.81 The most commonly funded services were case management (received by 77% of
households), rental assistance (58% of households), and security/utility deposits (22% of
households).82 Most recipients participated in HPRP for 30 days or fewer (44% of people), and
92% had exited the program within six months.83 Nearly 93% reported that they would be living
independently in permanent housing after leaving the program, compared to 66% of participants
who lived in their own home or apartment on the night prior to program entry.84 The report also
contains information on participant demographics and incomes.
Housing Vouchers for Persons Who Are Homeless
Another source of assistance for homeless individuals is targeted Section 8 vouchers. Vouchers
are portable housing subsidies that eligible households (those with very low- and extremely low-
incomes) can use to find rental housing in the private market.85 During the four most recent fiscal
years, FY2008 through FY2011, Congress has appropriated funds for Section 8 vouchers to be set
aside for homeless veterans. In each year from FY2008 through FY2010, Congress appropriated
$75 million, an amount sufficient to fund approximately 10,000 vouchers in each year. In
FY2011, Congress provided $50 million for vouchers for homeless veterans. (For more
information about these vouchers, see CRS Report RL34024, Veterans and Homelessness, by
Libby Perl.)
In the FY2011 and FY2012 Administration budgets, the President proposed to fund additional
Section 8 vouchers for two homeless populations: chronically homeless individuals and homeless
families with children. In FY2011, the President requested a total of $85 million to fund a set
77 Ibid., pp. 5-6.
78 Ibid. p. 23.
79 Ibid., p. 20.
80 U.S. Department of Housing and Urban Development, The 2010 Annual Homeless Assessment Report to Congress,
June 2011, http://www.nytimes.com/2011/06/22/health/policy/22smoke.html.
81 Ibid., p. 57.
82 Ibid., p. 64.
83 Ibid., pp. 65-66.
84 Ibid., pp. 60, 67.
85 For more information about Section 8 vouchers, see CRS Report RL32284, An Overview of the Section 8 Housing
Programs: Housing Choice Vouchers and Project-Based Rental Assistance, by Maggie McCarty.
Congressional Research Service
19
.
The HUD Homeless Assistance Grants: Distribution of Funds
aside of 4,000 vouchers for chronically homeless adults and 6,000 vouchers for families with
children who are homeless or at risk of homelessness.86 Congress did not appropriate funds for
vouchers in FY2011.87
The President’s FY2012 proposal is similar. It would create a demonstration program that would
provide $57 million to fund a total of 7,500 vouchers as follows:
• Vouchers for Chronically Homeless Individuals with Disabling Conditions—The
Administration’s proposal would make vouchers available to single homeless
individuals considered chronically homeless and who are “enrolled in Medicaid
through coverage expansion under 1115 waivers or state only initiatives.”88
Participants would receive medical care through Medicaid, and HUD would also
partner with HHS to leverage assistance through the Substance Abuse and Mental
Health Services Administration (SAMHSA). A number of studies have found that
chronically homeless individuals who move into supportive housing reduce their
reliance on, and the cost to, hospitals and nursing homes, among other services.89
• Vouchers for Families with Children Who Are Homeless or At Risk of
Homelessness—In administering these vouchers, HUD would collaborate with
HHS and the Department of Education (ED) to provide housing and services to
families. ED would help identify students in families who might be in need of
assistance, and PHAs would collaborate with local HHS-funded programs such
as Temporary Assistance for Needy Families (TANF), child care services, Head
Start, employment and training programs, health care, and substance abuse
counseling to provide assistance to family members.
The proposal would require an evaluation of both programs to determine cost savings,
replicability, and potential cost-sharing among federal agencies.
86 U.S. Department of Housing and Urban Development, FY2011 Budget Justifications for Tenant-Based Rental
Assistance, pp. J-21 to J-23, http://hud.gov/offices/cfo/reports/2011/cjs/tennant-based-assistance2011.pdf.
87 Prior to enactment of P.L. 112-10, Department of Defense and Full-Year Continuing Appropriations Act, the
FY2011 House-passed HUD appropriations bill (H.R. 5850) and the Senate Appropriations Committee-passed bill (S.
3644) would have provided $85 million to fund the two voucher demonstration programs.
88 U.S. Department of Housing and Urban Development, FY2012 Budget Justifications for Tenant-Based Rental
Assistance, p. H-18, http://portal.hud.gov/hudportal/documents/huddoc?id=Tenant_BR_Assis_2012.pdf.
89 See, for example, Dennis Culhane, Stephen Metraux, and Trevor Hadley, “Public Service Reductions Associated
with Placement of Homeless Persons with Severe Mental Illness in Supportive Housing,” Housing Policy Debate, vol.
13, no. 1 (2002), pp. 107-163; Mary E. Larimer, Daniel K. Malone, and Michelle D. Garner et al., “Health Care and
Public Service Use and Costs Before and After Provision of Housing for Chronically Homeless Persons with Severe
Alcohol Problems,” Journal of the American Medical Association, vol. 301, no. 13 (April 1, 2009), pp. 1349-1357; and
Tia E. Martinez and Martha R. Burt, “Impact of Permanent Supportive Housing on the Use of Acute Care Health
Services by Homeless Adults,” Psychiatric Services, vol. 57, no. 7 (July 2006), pp. 992-999.
Congressional Research Service
20
.
Figure 1. Distribution of the HUD Homeless Assistance Grants
Source: Chart prepared by CRS on the basis of 42 U.S.C. § 11373 and the FY2010 HUD NOFA. Percentages are based on the FY2010 distribution of the Homeless
Assistance Grants.
CRS-21
.
The HUD Homeless Assistance Grants: Distribution of Funds
Reauthorization of the McKinney-Vento Homeless
Assistance Grants
On April 2, 2009, identical versions of bills to reauthorize the McKinney-Vento Homeless
Assistance Grants were introduced in both the House and Senate. The two bills, H.R. 1877 and S.
808, were both entitled the Homeless Emergency Assistance and Rapid Transition to Housing
(HEARTH) Act. On May 6, 2009, Senator Reed, the sponsor of S. 808, proposed adding the bill
as an amendment to S. 896, the Helping Families Save Their Homes Act, which was being
considered by the full Senate.90 Senator Reed’s amendment was approved, and later that same day
the Senate approved S. 896. The House approved S. 896 on May 19, 2009, and, due to small
differences between the House- and Senate-passed versions, the Senate approved the House-
passed measure that same day. On May 20, 2009, the President signed the bill into law as P.L.
111-22. Prior to this, the Homeless Assistance Grants had not been reauthorized since 1992 (P.L.
102-550). The changes in the HEARTH Act technically became effective as of November 20,
2010 (the law specified that provisions would take effect at the earlier of 18 months after
enactment or three months from the date on which HUD publishes final regulations). However,
HUD has stated that until new regulations become effective, the current regulations governing the
Homeless Assistance Grants, including the definition of homelessness, continue in place.
The changes in P.L. 111-22 will have repercussions for the makeup of the Homeless Assistance
Grants (the three competitive grants will be consolidated into one grant), the way in which funds
are distributed to grantees, the purposes for which grantees may use funds, and the determination
of who may be served under the law. This section describes the major changes that the HEARTH
Act makes to the Homeless Assistance Grants.
Consolidation of the Competitive Homeless Assistance Grants
The HEARTH Act removes the distinctions among the three competitive Homeless Assistance
Grants and replaces them with one consolidated grant program called the “Continuum of Care
Program.” Applicants will no longer apply for one of the three existing grants—S+C, SHP, or
SRO—based on the type of housing and services they want to provide. Instead, the new
consolidated grant will provide funds for all permanent housing, transitional housing, supportive
services, and re-housing activities.
In consolidating the competitive grants, the HEARTH Act will maintain some aspects of the
current Continuum of Care application system and will codify the system in law (currently much
of the application system has been established through the grant funding process). Under P.L.
111-22, HUD will review applications from Collaborative Applicants—local entities that will
determine funding priorities and jointly submit a single application to HUD on behalf of all local
applicant organizations (much like the existing Continuum of Care). Currently, although CoCs
submit one application to HUD, the Department must still review the individual project
applications from organizations seeking funding. This change from separate project applications
to a single Collaborative Applicant application will mean the difference between HUD reviewing
90 See S.Amdt. 1040.
Congressional Research Service
22
.
The HUD Homeless Assistance Grants: Distribution of Funds
hundreds rather than thousands of applications.91 Collaborative Applicants may also choose to
apply to HUD to be “Unified Funding Agencies;” the Unified Funding Agencies will have
authority to receive grant awards directly from HUD and distribute them to individual awardee
organizations. Otherwise, HUD will continue using its current practice of distributing funds
directly to individual project applicants.
P.L. 111-22 will also require certain set-asides within the Continuum of Care Program to provide
housing for homeless populations.
• At least 30% of funds (not including those for permanent housing renewals) must
be used to provide permanent supportive housing to individuals with disabilities
or families with an adult head of household (or youth in the absence of an adult)
who has a disability. This requirement will be reduced proportionately as
communities increase permanent housing units for those individuals and families,
and will end when HUD determines that a total of 150,000 permanent housing
units had been provided for homeless persons with disabilities since 2001.
• At least 10% of funds must be used to provide permanent housing for families
with children.
Collaborative Applicants that are successful in reducing or eliminating homelessness through
permanent housing will receive bonuses that they can use for any eligible activity under the
Continuum of Care Program as well as homelessness prevention activities.
P.L. 111-22 also institutes a new program to allow certain high-performing communities to have
greater flexibility in the way that they use their funds. To be designated high-performing, a
Collaborative Applicant will have to meet requirements regarding the average length of
homelessness in their communities, repeat instances of homelessness, community involvement
and outreach activities, effectiveness in reducing homelessness, and success in achieving
independent living among homeless families with children and youth. Collaborative Applicants
designated “high performing” will be able to use their grant awards for any eligible activity under
the Continuum of Care Program, as well as for homelessness prevention activities.
Regarding the pro rata need process currently used to determine how funds are distributed to
communities (which uses the CDBG formula, in part, to determine need), the HEARTH Act
requires HUD to create a new formula for determining need within two years of the bill’s
enactment using “factors that are appropriate to allocate funds to meet the goals and objectives
of” the Continuum of Care program. P.L. 111-22 gives the HUD Secretary the authority to adjust
the formula to ensure that Collaborative Applicants have sufficient funds to renew existing
contracts for one year.
The HEARTH Act authorized the Continuum of Care Program, together with the Emergency
Solutions Grants Program (described below) at $2.2 billion in FY2010 and such sums as
necessary for FY2011. P.L. 111-22 provides that renewals of permanent housing contracts may be
funded through either the Homeless Assistance Grants account or the project-based Section 8
account.
91 The HEARTH Act also allows individual organizations to apply directly to HUD for funds if they are not reasonably
permitted to participate as part of the collaborative application process.
Congressional Research Service
23
.
The HUD Homeless Assistance Grants: Distribution of Funds
Definition of “Homeless Individual” and “Chronically
Homeless Person”
The HEARTH Act expands the definition of “homeless individual” that was codified in the
McKinney-Vento Homeless Assistance Act when the law was originally enacted.92 Under the
original law, a homeless individual was defined as an individual who lacks a fixed, regular, and
adequate nighttime residence and who resides in a temporary shelter (including welfare hotels,
congregate shelter, and transitional housing for those with mental illnesses), resides in an
institution as a temporary residence, or a in place not designed for human habitation. This
definition was sometimes described as requiring one to be literally homeless in order to meet its
requirements93—either living in emergency accommodations or having no place to stay. The
HEARTH Act maintains this portion of the definition, but also broadens the McKinney-Vento Act
definition, moving away from the requirement for literal homelessness.
• Transitional Housing: The HEARTH Act amends the current definition of
homeless individual to include all those persons living in transitional housing, not
just those residing in transitional housing for the mentally ill as in prior law.
• Hotel/Motel: The new law also includes in the definition persons living in hotels
or motels paid for by a government entity.
• Imminent Loss of Housing: P.L. 111-22 adds to the current definition those
individuals and families who meet all of the following criteria. (1) They will
“imminently lose their housing,” whether it be their own housing, housing they
are sharing with others, or a hotel or motel not paid for by a government entity.
Imminent loss of housing is evidenced by an eviction requiring an individual or
family to leave their housing within 14 days; a lack of resources that would allow
an individual or family to remain in a hotel or motel for more than 14 days; or
credible evidence that an individual or family would not be able to stay with
another homeowner or renter for more than 14 days. (2) They have no subsequent
residence identified. (3) They lack the resources needed to obtain other
permanent housing. (HUD practice prior to passage of the HEARTH Act was to
consider those individuals and families who would imminently lose housing
within seven days to be homeless.)
• Domestic Violence: Another change to the definition of homeless individual is
that the HEARTH Act considers homeless anyone who is fleeing a situation of
domestic violence or other life-threatening condition.
• Other Federal Definitions: In addition, P.L. 111-22 adds to the definition of
homeless individual unaccompanied youth and homeless families with children
who are defined as homeless under other federal statutes and who (1) have
experienced a long-term period without living independently in permanent
housing; (2) have experienced instability as evidenced by frequent moves; and
(3) can be expected to continue in unstable housing due to factors such as chronic
disabilities, chronic physical health or mental health conditions, substance
92 42 U.S.C. § 11302.
93 See, for example, the Department of Housing and Urban Development, The Third Annual Homeless Assessment
Report to Congress, July 2008, p. 2, footnote 5, http://www.hudhre.info/documents/
3rdHomelessAssessmentReport.pdf.
Congressional Research Service
24
.
The HUD Homeless Assistance Grants: Distribution of Funds
addiction, histories of domestic violence or childhood abuse, the presence of a
child or youth with a disability, or multiple barriers to employment. In general,
however, Collaborative Applicants will not be able to use more than 10% of grant
funds to serve those individuals and families defined as homeless under other
federal statutes.
P.L. 111-22 also expands the current definition of “chronically homeless person,” which is
defined in regulation.94 Under the regulation, the term had been defined as an unaccompanied
individual who has been homeless continuously for one year or on four or more occasions in the
last three years, and who has a disability. The HEARTH Act adds to the definition those homeless
families with an adult head of household (or youth where no adult is present) who has a disability.
The definition of disability specifically includes post traumatic stress disorder and traumatic brain
injury. Note, however, that to be considered chronically homeless, an individual or family has to
be living in a place not meant for human habitation, a safe haven, or an emergency shelter; the
HEARTH Act’s proposed changes to the definition of “homeless individual” do not apply to
chronic homelessness. In addition, a person released from an institution will be considered
chronically homeless as long as, prior to entering the institution, they otherwise met the definition
of chronically homeless person, and had been institutionalized for fewer than 90 days.
On April 20, 2010, HUD published a proposed rule to clarify the changed definition in the
HEARTH Act; the comment period ended on June 21, 2010.95
Homelessness Prevention
The HEARTH Act also expands the opportunities for grantees to engage in homelessness
prevention activities. Currently, only ESG funds may be used for homelessness prevention
activities such as payment of rent or utility bills, limited to 30% of a state’s or a community’s
allocation. P.L. 111-22 expands the eligible activities and funding level of the Emergency Shelter
Grants Program and renames it the “Emergency Solutions Grants Program.” The new law
allocates 20% of funds made available by Congress for the Homeless Assistance Grants to the
newly-named program (currently somewhere between 10% and 15% of funds are reserved for the
ESG program). P.L. 111-22 expands the list of supportive services that can be provided with ESG
program funds from those concerned with “employment, health, drug abuse, or education,” to
include family support services for homeless youth, victim services, and mental health services.
The new ESG program also allows funds to be used for short- or medium-term rental assistance
and housing relocation and stabilization services for individuals and families at risk of
homelessness. The bill defines the term “at risk of homelessness” to include an individual or
family with income at or below 30% of area median income, who has insufficient income to
attain housing stability, who has moved frequently for economic reasons, and who lives in
unstable housing (examples of unstable housing are enumerated in the law). The term also
includes all individuals and families defined as homeless under other federal statutes as “at risk.”
Under the updated ESG program in the HEARTH Act, the amount of funds that grant recipients
can use for emergency shelter and related supportive services are limited, thereby requiring that a
portion of funds be used for rental assistance and services for those at risk of homelessness.
94 24 C.F.R. § 91.5.
95 U.S. Department of Housing and Urban Development, “Homeless Emergency Assistance and Rapid Transition to
Housing: Defining “Homeless”,” 75 Federal Register 20541-20546, April 20, 2010.
Congressional Research Service
25
.
The HUD Homeless Assistance Grants: Distribution of Funds
Specifically, recipients cannot use more than the greater of 60% of their ESG allocation, or the
amount they had used prior to enactment of the HEARTH Act, for emergency shelter and related
services.
Rural Homelessness
In the area of rural homelessness, the HEARTH Act retains portions of McKinney-Vento’s rural
homelessness grant program (Title IV, Subtitle G of McKinney-Vento), a program that has not
been funded, as the Rural Housing Stability Assistance Program. The program reserves not less
than 5% of Continuum of Care Program funds for rural communities to apply separately for funds
that would otherwise be awarded as part of the Continuum of Care Program. Unlike the
Continuum of Care program, rural communities will be able to serve persons who do not
necessarily meet HUD’s definition of “homeless individual.” P.L. 111-22 provides that HUD may
award grants to rural communities to be used for (1) re-housing or improving the housing
situation of those who are homeless or are in the worst housing situations in their geographic
area, (2) stabilizing the housing situation of those in imminent danger of losing housing, and (3)
improving the ability of the lowest-income residents in the community to afford stable housing.
The HEARTH Act adds to the list of eligible activities under the rural grants the construction or
rehabilitation of transitional or permanent housing as well as the leasing of property or payment
of rental assistance for these purposes.
Other Issues Regarding the Homeless
Assistance Grants
Despite the enactment of McKinney-Vento reauthorization legislation, there are other factors
involved in the distribution of the Homeless Assistance Grants that may continue to be issues of
concern to those interested in how funds are allocated. An ongoing concern has been the amount
of funds required to renew existing housing and services contracts, leaving a relatively small
share of funding to support new projects. Another issue is the way in which the CDBG formula
affects the distribution of the Homeless Assistance Grants. While enactment of the HEARTH Act
may mean that the CDBG formula will not be used in the distribution of competitive funds in the
future, the CDBG formula will continue to be used to distribute ESG funds.
Renewals of the Competitive Homeless Assistance Grants
In recent years Congress has shown some concern about the cost of renewing existing permanent
supportive housing contracts through the S+C and SHP programs, while also funding new
permanent housing units.96 Currently a large percentage of competitive Homeless Assistance
Grant funds are used to renew existing SHP and S+C contracts. For example, in FY2009 nearly
87% of competitive grant funds were used to renew existing contracts. (For the percentage
96 In order to better anticipate the need for renewal funds, beginning in FY2002, Congress asked HUD to estimate five-
year projections for renewing SHP and S+C contracts. Conference Report to accompany H.R. 2620, Department of
Veterans’ Affairs, Housing and Urban Development, and Independent Agencies Appropriation Act, 107th Cong., 1st
sess., November 6, 2001, H.Rept. 107-272. HUD has provided these estimates in its Congressional Budget
Justifications for FY2003, and from FY2006 through the present.
Congressional Research Service
26
.
The HUD Homeless Assistance Grants: Distribution of Funds
allocation of the FY2010 competitive grants, see Figure 2.) In its FY2012 budget, HUD
estimated that approximately $1.8 billion would be needed to renew existing S+C and SHP
contracts in FY201197 (nearly the entire amount appropriated for the Homeless Assistance
Grants).
HUD has changed the way it calculates pro rata need in order to help CoCs to free up funds for
new permanent housing projects. Beginning with the FY2005 competition for available funds,
HUD enabled CoCs to eliminate funding for existing SHP projects from their priority lists while
still qualifying for the hold harmless level of pro rata need funds that would have been required to
renew those SHP projects. This enabled the funds that otherwise would have been directed toward
renewals to be used to create new permanent housing projects.98 Although this allowed CoCs to
defund projects that they did not think should receive grants, it did not address what CoCs can do
about renewing projects they think are worth funding while also funding projects that would
create new housing. HUD allowed this reallocation of funds through the FY2008 competition and
again in FY2010.
The HEARTH Act also introduced a way in which Homeless Assistance Grant funds could be
freed up for new projects. Under the new law, renewals of permanent housing rental assistance
and operating cost contracts could be funded from the Section 8 project-based rental assistance
account. This assumes that appropriations for the Homeless Assistance Grants would remain at
similar levels despite transfer of the renewals to another account.
97 U.S. Department of Housing and Urban Development, FY2012 Congressional Budget Justifications for Homeless
Assistance Grants, p. Y-11, http://portal.hud.gov/hudportal/documents/huddoc?id=Homeless_Assis_Grants_2012.pdf.
98 U.S. Department of Housing and Urban Development, “Notice of Funding Availability, Continuum of Care
Homeless Assistance,” Federal Register, vol. 70, no. 53, March 21, 2005, pp. 14283-14284.
Congressional Research Service
27
.
The HUD Homeless Assistance Grants: Distribution of Funds
Figure 2. FY2010 Percentage Allocation of Competitive Grants
Source: CRS analysis of HUD FY2010 grant announcements, available at http://portal.hud.gov/hudportal/
documents/huddoc?id=press_report2010.pdf, and http://www.hud.gov/offices/cpd/homeless/budget/2010/
10_all_grants.pdf.
The Role of the Community Development Block Grant Formula
The Community Development Block Grant (CDBG) formula has determined how ESG funds are
distributed since the inception of the program in 1986, and has been used in the distribution of the
competitive grants since at least FY1995. The effectiveness of using the CDBG formula to target
funds to services for homeless persons has been questioned at various times. Two General
Accounting Office (now Government Accountability Office) reports from the late 1980s noted
that the CDBG formula might not be the best way to target funds to areas that most need
homeless assistance funds.99 Congress, too, has questioned the relationship between the formula
and homelessness. In FY2001, the Senate Appropriations Committee noted that “the CDBG
formula has no real nexus to homeless needs,” and urged HUD to hasten its development of a
method for counting homeless individuals.100 HUD responded with a report that proposed
alternative methods for determining community need for homeless assistance.101
The newly-enacted HEARTH Act (P.L. 111-22) responded to these concerns, in part by directing
HUD to develop a formula for determining need for the competitive Continuum of Care Program
within two years of the law’s enactment. As discussed earlier in this report, the competitive
99 U.S. General Accounting Office, Homelessness: Implementation of Food and Shelter Programs Under the McKinney
Act. GAO/RCED-88-63. December 1987, p. 33, http://archive.gao.gov/d29t5/134578.pdf, and Homelessness: HUD’s
and FEMA’s Progress in Implementing the McKinney Act. GAO/RCED-89-50. May 1989, pp. 46-48,
http://archive.gao.gov/d25t7/138597.pdf.
100 S.Rept. 106-410. The statement was made regarding the competitive Homeless Assistance Grants.
101 U.S. Department of Housing and Urban Development. Office of Community Planning and Development. Report to
Congress: Measuring “Need” for HUD’s McKinney-Vento Homeless Competitive Grants, 2001.
Congressional Research Service
28
.
The HUD Homeless Assistance Grants: Distribution of Funds
Homeless Assistance Grants currently use the CDBG formula to determine a community’s need
for funds. However, the competitive grants will continue to use the CDBG formula until HUD
implements a new formula, and the HEARTH Act does not change the use of the CDBG formula
to distribute ESG funds.
The CDBG formula has also been questioned as the best way of targeting funds for its intended
purpose—community development—and changing the formula has been the subject of discussion
for a number of years. The current formula factors used to distribute funds are: population, the
number of persons in poverty, housing overcrowding (homes in which there are more than 1.01
persons per room), the age of housing (the number of housing structures built prior to 1940), and
the extent of growth lag in a given community (the lack of population growth in a community
compared to the growth rate it would have had if it had grown at the rate of other
communities).102 In 2005, HUD released a report in which it examined the effectiveness of the
CDBG formula in targeting communities that are in need of development. Among the report’s
criticisms of the formula was that the use of the population variable means that some fast-
growing communities with low development needs may still receive increasing CDBG grants.103
Another criticism was that the poverty variable may provide college towns with a
disproportionate share of funds by counting college students as living in poverty.104 A third
potential problem with the formula the report noted was that the age of housing and growth lag
factors do not necessarily reflect communities’ needs for development. In some communities,
housing built prior to 1940 has been rehabilitated and gentrified, while in others it has been torn
down or subject to neglect.105 As a result, some communities with refurbished pre-1940s housing
may qualify for more CDBG funds than deteriorating communities that have demolished their
older housing.
The 2005 HUD report also proposed alternative factors for the CDBG formula.106 Among these
was a formula that would not require a split of funds between entitlement communities (which
currently receive 70% of funds) and non-entitlement communities (which receive 30% of funds)
and would use the following factors:
• the number of people in poverty, excluding college students;
• housing that is 50 years old or older and occupied by a household in poverty;
• female-headed households with children under the age of 18; and
• overcrowding.
The President’s FY2010 budget proposed to change the CDBG formula and replace it with this
HUD-proposed formula.107 The budget proposed that the CDBG formula be modernized to
“better target funds to communities with the greatest economic need,” and noted that any new
formula would include hold-harmless provisions to allow transition time for communities that
102 42 U.S.C. § 5306.
103 Todd Richardson, CDBG Formula Targeting to Community Development Need, U.S. Department of Housing and
Urban Development, February 2005, p. 46, http://www.huduser.org/Publications/pdf/CDBGAssess.pdf.
104 Ibid., p. 47.
105 Ibid., pp. 48-50.
106 Ibid., pp. 61-84.
107 FY2010 HUD Budget Justifications, p. Q-10.
Congressional Research Service
29
.
The HUD Homeless Assistance Grants: Distribution of Funds
might receive a lower share of total funds to adjust to the revised allocations. The
recommendations were not taken up by Congress.
Author Contact Information
Libby Perl
Specialist in Housing Policy
eperl@crs.loc.gov, 7-7806
Congressional Research Service
30