HUD’s Consolidated Planning Process: An Overview

May 20, 2024 R48073

HUD’s Consolidated Planning Process:
An Overview
May 20, 2024
Congressional Research Service
https://crsreports.congress.gov
R48073

Department of Housing and Urban Development Consolidated Plan: An Overview

R48073
HUD’s Consolidated Planning Process:
May 20, 2024
An Overview
Joseph V. Jaroscak,
The Department of Housing and Urban Development (HUD) Office of Community Planning and
Coordinator
Development (CPD) administers several formula grant programs that provide funds to states or
Analyst in Economic
eligible local governments (grantees) to address certain housing or community development
Development Policy
needs. As a prerequisite for receipt of these funds, each state, local government, and consortium

of local governments that receives funds through at least one of five HUD formula grant
Katie Jones
programs—the Community Development Block Grant (CDBG), the HOME Investment
Analyst in Housing Policy
Partnerships Program, Emergency Solutions Grants, Housing Opportunities for Persons with

AIDS, and the Housing Trust Fund—is required to submit to HUD a Consolidated Plan that
details its housing needs and planned uses of program funds. The Consolidated Plan contains
Libby Perl
planning, strategy, and reporting components, which are guided by input from residents and
Specialist in Housing Policy
consultation with practitioners. Over 1,200 grantees receive funds through one or more of these

programs and each prepares a Consolidated Plan.

In developing its Consolidated Plan, a CPD grantee must seek public input and consult with
relevant public and private entities. The Consolidated Plan process has several components that progress from collecting
information and data about housing conditions and needs in the grantee’s jurisdiction (Homeless and Housing Needs
Assessment and Housing Market Analysis), to planning for use of federal funds to address the identified needs (the Strategic
Plan), and reporting on activities planned for the upcoming program year (the Annual Action Plan). Consolidated Plans
typically cover a five-year period, although the Annual Action Plan and a performance report (the Consolidated Annual
Performance and Evaluation Report, or CAPER) are submitted annually. HUD reviews grantees’ Consolidated Plans to
ensure that they comply with certain statutory requirements, contain required certifications, and are not substantially
incomplete.
HUD established the current consolidated planning process in 1995. The Consolidated Plan replaced previous planning and
reporting requirements that applied to the various HUD grant programs individually. The Consolidated Plan regulatory
requirements may vary, in some cases, by the type of grantee (state, local government, or consortium) or by grant program.
Congress may take an interest in potential changes to the Consolidated Plan’s contents or processes to ensure that it is
meeting its goals or reflecting current priorities. At times, Congress or HUD have expanded, or sought to expand, the types of
information or level of detail provided in the Consolidated Plan. Other federal efforts have sought to enhance regional and
interjurisdictional coordination as it pertains to plans and processes facilitated by other federal agencies.

Congressional Research Service

link to page 31 Department of Housing and Urban Development Consolidated Plan: An Overview

Introduction
The Department of Housing and Urban Development (HUD) administers a variety of programs
intended to address the housing needs of low-income households and other vulnerable
populations.1 These include a number of formula grant programs administered by HUD’s Office
of Community Planning and Development (CPD) that provide funds to states and/or eligible local
governments to address certain housing or community development needs.2
As a condition of receiving funds through these specific CPD formula grant programs, each state
and eligible local government, referred to collectively in this report as grantees, must submit a
Consolidated Plan to HUD. The Consolidated Plan, or Con Plan (this report uses both terms),
describes a jurisdiction’s housing and community development needs and how funds from the
formula grant programs will be used to address those needs. Consolidated Plans typically cover a
five-year period, although some components of the plan are submitted annually.
The Con Plan contains planning, strategy, and reporting components, and requires jurisdictions to
involve citizens and consult with other relevant entities in developing their plans. Using existing
statutory authority, HUD established the current consolidated planning process via regulations in
1995, replacing the planning and reporting requirements that had previously been in place for
these HUD grant programs.
Congress may take an interest in the consolidated planning process for a variety of reasons. While
the formula grant programs covered by the Consolidated Plan are intended to provide local
grantees with flexibility in choosing how to use program funds, the Consolidated Plan provides
HUD a mechanism for federal accountability and oversight. The federal requirements that govern
the Consolidated Plan (including the information to be included and who is to be consulted in the
process) therefore provide an avenue for federal policymakers to potentially influence local
decisionmaking. Congress may also take an interest in the extent to which the Consolidated Plan
advances coordination of federal resources, efficient use of federal funds, or other perceived
desirable outcomes, and whether there are factors—such as capacity constraints among local
grantees or at HUD, or gaps in the planning requirements themselves—that could impede such
outcomes. These considerations involve potential tradeoffs, such as that between the need for
federal oversight of program administration and the provision of local control, which is a defining
feature of the formula grant programs discussed in this report.
This report provides an overview of consolidated planning requirements. It begins with a brief
history of the Con Plan and the programs to which it applies. It then describes the consolidated
planning process and the required contents of the Consolidated Plan. It concludes with a
discussion of selected federal efforts or proposals to modify, expand, or clarify aspects of the
consolidated planning process. For a list of common terminology related to the Consolidated
Plan, see the Appendix.

1 For descriptions of programs administered by HUD, see U.S. Department of Housing and Urban Development,
Programs of HUD: Major Mortgage, Grant, Assistance, and Regulatory Programs, 2023, https://www.hud.gov/sites/
dfiles/Main/documents/HUDPrograms2023.pdf. For an overview of federal housing assistance programs more
generally, including those administered by HUD and other departments, see CRS Report RL34591, Overview of
Federal Housing Assistance Programs and Policy.
2 For grantee Consolidated Plans and associated documents, see HUD, CPD Consolidated Plans, Annual Action Plans,
and CAPERs, https://cpd.hud.gov/cpd-public/consolidated-plans.
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Department of Housing and Urban Development Consolidated Plan: An Overview

Where to Find Information on Grantees’ Consolidated Plans
Each of the over 1,200 state and local government grantees that receive funding through at least one covered
HUD formula grant program submits a Consolidated Plan.3 Grantees’ Consolidated Plans can be found on HUD’s
website at https://cpd.hud.gov/cpd-public/consolidated-plans. Grantee contact information is available at
https://www.hudexchange.info/grantees/contacts/. Those interested in providing input on a community’s
Consolidated Plan should look for information on citizen participation meetings from the grantee during the
planning process.
Programs Under the Consolidated Plan
The following five grant programs require a Consolidated Plan:4
1. Community Development Block Grant (CDBG);
2. HOME Investment Partnerships (HOME);
3. Housing Trust Fund (HTF);
4. Emergency Solutions Grant (ESG); and
5. Housing Opportunities for Persons with AIDS (HOPWA).
Under the Consolidated Plan, grantees’ planning and reporting requirements under each of these
separate formula grant programs are consolidated into one plan that each grantee is required to
submit to HUD. While the Consolidated Plan covers these five programs, certain other HUD
programs not included in the plan may require that applicants have an approved Consolidated
Plan in order to be eligible for funding, or may require program applications to include a
certification that the application is consistent with the approved Consolidated Plan.5
Community Development Block Grant (CDBG)
The CDBG program is a flexible source of federal funding provided to states, localities, and U.S.
territories for a broad range of economic and community development-related purposes. The
program was originally authorized under Title I of the Housing and Community Development Act
of 1974, P.L. 93-383, with the primary purpose of establishing and maintaining viable
communities through the implementation of activities that benefit low- and moderate-income
persons. The majority of CDBG program activities, generally, are grouped into six broad
categories: (1) planning and administrative activities; (2) public improvement activities; (3)
housing-related activities; (4) public services; (5) economic development; and (6) acquisition,
demolition, and disposition of real property. CDBG’s authorizing statute requires grantees to
certify that all proposed activities meet one of the program’s national objectives:

3 The largest of these programs, the Community Development Block Grant, provides funds to more than 1,200
grantees. HUD, 2025 Congressional Justifications, p. 18-1, https://www.hud.gov/sites/dfiles/CFO/documents/
2025_CJ_Program_-_CDF.pdf.
4 For the amounts of recent state and local formula allocations under these programs, see the links under “Formula
Program Allocations by Grantee” on HUD’s website at https://www.hud.gov/program_offices/comm_planning/budget.
Not all grantees receive funds through all five programs.
5 24 C.F.R. §§91.2(b) and 91.510. For example, local public housing authorities (PHAs) are required to submit PHA
plans as a condition of receiving public housing and Section 8 funding, and the PHA plan must include a certification
that its annual plan is consistent with the Consolidated Plan for the jurisdiction where the PHA is located (see 24 C.F.R.
§903.15).
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Department of Housing and Urban Development Consolidated Plan: An Overview

1. principally benefit low- and moderate-income persons (having income at or
below 80% of area median income);6
2. aid in the prevention or elimination of slums or blight; or
3. meet an urgent need by addressing conditions that pose a serious and immediate
threat to the health and safety of residents.7
Seventy percent of CDBG program formula funds are distributed to entitlement communities
(including the District of Columbia), defined as (1) principal cities of Metropolitan Statistical
Areas, (2) other metropolitan cities with populations of 50,000 or greater, and (3) urban counties
with populations of 200,000 or greater (excluding entitlement city populations within the county).
The remaining 30% of formula funds are allocated to states based on a separate formula
allocation process. State CDBG funds are to be distributed by states and Puerto Rico to units of
general local government—referred to as nonentitlement communities—that do not qualify to
receive entitlement funds directly from HUD. Before formula allocations are made to states and
localities, $7 million is statutorily set aside to be distributed among other U.S. territories.8
HOME Investment Partnerships Program (HOME)
The HOME Investment Partnerships Program, often just referred to as HOME, provides funds to
states, eligible local governments (or consortia of local governments), and U.S. territories to use
for a range of affordable housing activities that benefit low-income households. It was originally
authorized by the Cranston-Gonzalez National Affordable Housing Act of 1990 (P.L. 101-625).
Eligible activities include developing affordable housing for rental or homeownership, providing
homebuyer assistance, housing rehabilitation activities, and tenant-based rental assistance. All
HOME funds must be used for housing to be occupied by low-income households (households
with incomes at or below 80% of area median income), and at least 90% of HOME funds used for
rental housing activities must benefit households with incomes at or below 60% of area median
income.
HOME funds are distributed based on a formula that takes into account several factors related to
rental housing conditions and poverty in a jurisdiction. By law, HUD allocates 40% of funds to
states and the remaining 60% of funds to localities. (Puerto Rico and Washington, DC, are
considered states for the purposes of the HOME program.) Before HUD makes formula
allocations to states and localities, it sets aside the greater of $750,000 or 0.2% of the total HOME
appropriation to be distributed to the U.S. territories under a separate formula.
Housing Trust Fund (HTF)
The HTF provides funds to states and territories to use for certain affordable housing activities,
with a focus on rental housing for the lowest income households. It was established by the

6 CDBG grantees are required to ensure that 70% of its program funds principally benefit low- and moderate-income
persons in a one-, two-, or three-year period, although waivers may be obtained in extenuating circumstances. For
information on HUD’s definitions for low and moderate income, see https://www.hudexchange.info/programs/cdbg/
cdbg-low-moderate-income-data/.
7 42 U.S.C. §§5301 et seq., as interpreted by HUD at 24 C.F.R. §570.200 and the HUD Guide to National Objectives
and Eligible Activities for CDBG Entitlement Communities, https://www.hudexchange.info/resource/89/community-
development-block-grant-program-cdbg-guide-to-national-objectives-and-eligible-activities-for-entitlement-
communities/.
8 For CDBG and the other four HUD programs discussed in the report, the U.S. territories are American Samoa, Guam,
the Northern Mariana Islands, and the U.S. Virgin Islands. Under these programs, Puerto Rico is treated as a state.
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Department of Housing and Urban Development Consolidated Plan: An Overview

Housing and Economic Recovery Act of 2008 (P.L. 110-289).9 Most funds must be used to
produce, preserve, or rehabilitate rental housing, or for related operating costs.10 By law, 75% of
funds used for rental housing are to benefit extremely low-income households; by regulation,
HUD requires that all funds benefit extremely low-income households in years when less than $1
billion is provided (as of the cover date of this report, the Housing Trust Fund has never received
$1 billion or more in a given year).
HTF funds are distributed to states (including Puerto Rico and Washington, DC) based on a
formula that takes into account several factors related to rental housing conditions for extremely
low- and very low-income renter households in a state. Funding for the U.S. territories is
distributed by a different formula.
Emergency Solutions Grant (ESG)
The ESG program provides funds to states and localities to address the needs of people
experiencing homelessness. ESG (originally called Emergency Shelter Grants) was established
and funded as part of the FY1987 Continuing Appropriations Act, and was authorized one year
later through the McKinney-Vento Homeless Assistance Act (McKinney-Vento, P.L. 100-77).
Funds may be used for the renovation, major rehabilitation, or conversion of buildings into
emergency shelters; services such as employment counseling, health care, and education; and
homelessness prevention activities such as assistance with rent and utility payments.
The distribution of ESG funds is based on the CDBG formula. As with CDBG, entitlement
communities, states, and U.S. territories are eligible for funds. Entitlement community and state
allocations are based on their share of CDBG funds from the previous fiscal year. However, an
entitlement community must have received at least 0.05% of the previous year’s total CDBG
appropriation in order to receive their own allocation of ESG funds.11 U.S. territories are also
separately eligible for a set-aside of ESG funds.
Housing Opportunities for Persons with AIDS (HOPWA)
HOPWA provides housing and services specifically for people living with HIV/AIDS and their
families. HOPWA was established in 1990 as part of the Cranston-Gonzalez National Affordable
Housing Act (P.L. 101-625). Among the ways in which grantees can use funds are for rental
assistance in permanent housing; the development of single-room occupancy or community
residences; short-term rental, mortgage, or utility assistance or residence in short-term housing
facilities; supportive services; and housing counseling and referral services.12
The majority of HOPWA funds (90%) are distributed via formula. Eligible grantees include (1)
the most populous unit of local government within metropolitan statistical areas (MSAs) with
populations greater than 500,000 and more than 2,000 cases of people living with HIV or AIDS;
and (2) states with more than 2,000 cases of people living with HIV or AIDS outside of MSAs.13
Units of local government that receive HOPWA funds are required to allocate funds “in a manner

9 The Housing Trust Fund is funded through required annual contributions from two government-sponsored enterprises,
Fannie Mae and Freddie Mac, rather than through appropriations. See 12 U.S.C. §4567.
10 By law, up to 10% of funds can be used for certain homeownership activities. HUD regulations limit the use of funds
for operating costs to no more than one-third of a recipient’s annual grant amount.
11 42 U.S.C. §11373(b).
12 42 U.S.C. §12904.
13 42 U.S.C. §12903(c).
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Department of Housing and Urban Development Consolidated Plan: An Overview

that addresses the needs within the metropolitan statistical area in which the city is located.”14 For
the purposes of the HOPWA program, the District of Columbia is considered an MSA and Puerto
Rico is defined as a state. MSAs within the territories may also qualify for assistance.
History of the Consolidated Plan
HUD established the current consolidated planning process in 1995, replacing existing planning
and reporting requirements that had applied to these HUD grant programs. Those planning and
reporting requirements had evolved over time through both statute and regulation.15
Of the five formula grant programs covered by the current Consolidated Plan, CDBG was the first
to be established, in 1974. As a condition of receiving CDBG funds, the CDBG authorizing
statute required grantees to submit to HUD a planning document called a Housing Assistance
Plan (HAP) that described the community’s housing needs and planned uses of CDBG funds. In
the late 1980s, the McKinney-Vento Act established certain programs targeting homelessness,
including ESG. The law required communities to submit a Comprehensive Homeless Assistance
Plan (CHAP) to receive McKinney-Vento funds. In 1990, Congress enacted the Cranston-
Gonzalez National Affordable Housing Act (NAHA) with a range of affordable housing
provisions. Among other things, NAHA established the HOME and HOPWA programs.
In addition to establishing HOME and HOPWA, NAHA also required communities receiving
funds from certain HUD programs to prepare a comprehensive housing plan called the
Comprehensive Housing Affordability Strategy (CHAS) as a condition of receiving funds.16 The
programs the CHAS applied to included CDBG (replacing the HAP), McKinney-Vento programs
(replacing the CHAP), and the newly created HOME and HOPWA programs. The NAHA
language establishing the CHAS included certain consultation and citizen participation
requirements. However, while the CHAS consolidated the planning requirements for these
programs, HUD continued to require certain additional submissions, including performance
reports, for the individual programs that were subject to the CHAS.
In 1995, after consultations with stakeholders, HUD replaced the regulations implementing the
CHAS to establish a new Consolidated Plan.17 The regulations consolidated and streamlined the
planning, strategy, and reporting requirements that applied to each of these programs and replaced
several documents that grantees had been required to submit under the various programs.
According to HUD:
This new consolidated submission will replace the current CHAS, the HOME program
description, the Community Development plan and the CDBG final statement, and the ESG
and HOPWA applications. The rule also consolidates the reporting requirements for these

14 42 U.S.C. §12903(f).
15 For more discussion about the history and the evolution of planning requirements for HUD formula grant programs,
see Margery Austin Turner, G. Thomas Kingsley, Monte L. Franke, et al., Planning to Meet Local Housing Needs: The
Role of HUD’s Consolidated Planning Requirements in the 1990s, The Urban Institute Metropolitan Housing and
Communities Policy Center, Submitted to HUD, Final Report, Washington, DC, December 2002,
https://www.huduser.gov/portal//Publications/pdf/local_housing_needs.pdf.
16 42 U.S.C. §12705.
17 Department of Housing and Urban Development, “Consolidated Submission for Community Planning and
Development Programs,” 60 Federal Register 1878-1919, January 5, 1995, https://www.govinfo.gov/content/pkg/FR-
1995-01-05/pdf/94-32150.pdf. (The Federal Register notice is erroneously dated January 5, 1994, but was actually
published on January 5, 1995. A correction to the date is at 60 Federal Register 2813, https://www.govinfo.gov/
content/pkg/FR-1995-01-11/pdf/X95-30111.pdf.)
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Department of Housing and Urban Development Consolidated Plan: An Overview

programs, replacing five general performance reports with one performance report. Thus,
in total, the consolidated plan and consolidated report will replace 12 documents.18
Although the CHAS has been replaced by the Consolidated Plan, the legislative language that
established the CHAS continues to provide the statutory underpinning for the Consolidated Plan.
Furthermore, the data that HUD provides to grantees to assist in their consolidated planning
process continues to be referred to as the “CHAS data.”19
When the Housing Trust Fund was established in 2008, the law required states to submit an
allocation plan in order to receive HTF funding.20 HUD implemented this requirement by
amending the Consolidated Plan regulations to include the HTF allocation plan in the
Consolidated Plan.21
Consolidated Plan Process
The HUD Consolidated Plan facilitates grantee decisionmaking based on data and public input.
HUD guidance describes the Consolidated Plan and its components as “part of a larger grants
management and planning process,” under which grantees collect information to plan, carry out,
and monitor HUD program activities.22 Depending on the specific formula grant, grantees may be
states, local governments, or, in the case of HOME, grantees may be consortia made up of
multiple contiguous local governments.23 The required Consolidated Plan process and contents
differ somewhat based on the type of grantee (state, local government, or consortium), and some
information may only be required for certain grant programs.
Generally, the process as described in HUD guidance includes the following action items:
• consultation and citizen participation;
• determination of needs;
• establishment of priorities;
• identification of resources;
• development of goals;
• administration of programs; and
• evaluation of performance.24

18 60 Federal Register 1878.
19 The CHAS data can be found on HUD’s website at https://www.huduser.gov/portal/datasets/cp.html.
20 The Housing Trust Fund was established by the Housing and Economic Recovery Act of 2008 (P.L. 110-289). The
requirement that states submit an allocation plan is at 12 U.S.C. §4568(c)(5).
21 See Department of Housing and Urban Development, “Housing Trust Fund,” Proposed Rule, 75 Federal Register
66981, October 29, 2010, https://www.govinfo.gov/content/pkg/FR-2010-10-29/pdf/2010-27069.pdf; and Department
of Housing and Urban Development, “Housing Trust Fund,” Interim Rule, 80 Federal Register 5200-5244, January 30,
2015, https://www.govinfo.gov/content/pkg/FR-2015-01-30/pdf/2015-01642.pdf.
22 HUD, The eCon Planning Suite: A Desk Guide for Using IDIS to Prepare the Consolidated Plan, Annual Action
Plan, and CAPER/PER, August 27, 2013, p. 24, https://www.hud.gov/sites/documents/
20394_CONPLAN_MANUAL.PDF.
23 For the purposes of the HOME program, one or more units of general local government that do not qualify for direct
allocations of HOME funds on their own may form a consortium for the purposes of qualifying for HOME funds,
subject to certain requirements. The consortium members must be geographically contiguous to one another. See 24
C.F.R. §92.101.
24 HUD, The eCon Planning Suite: A Desk Guide for Using IDIS to Prepare the Consolidated Plan, Annual Action
(continued...)
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Department of Housing and Urban Development Consolidated Plan: An Overview

Figure 1 provides a visualization of the action items included in the grants management process
associated with the Consolidated Plan and illustrates how citizen participation and consultation is
central to the process.
Figure 1. HUD Consolidated Planning Process
Visualization of Action Items

Source: Congressional Research Service (adapted from HUD’s Office of Community Planning and
Development, “A Desk Guide for Using IDIS to Prepare the Consolidated Plan, Annual Action Plan, and
CAPER/PER,” at https://www.hud.gov/sites/documents/20394_CONPLAN_MANUAL.PDF).
Notes: As indicated in HUD guidance, these steps may occur simultaneously and at various points in the year.
Grantees engage in this process through the development and implementation of four primary
documentation components:
1. citizen participation plan;
2. Consolidated Plan;
3. annual action plan; and
4. consolidated annual performance and evaluation report (CAPER).
Certain components documenting different stages of the Consolidated Plan process must be
submitted at least once every five years, while others must be submitted annually.25 Each
consolidated planning process begins with stakeholder consultation and citizen participation. The
Consolidated Plan regulations require grantees to submit summaries of the consultation and
citizen participation process, action plans, and any relevant certifications on an annual basis.26
Grantees report annually on their performance in the previous program year in the CAPER, as
required in the regulations.27 Figure 2 provides an illustration of the Consolidated Plan process

Plan, and CAPER/PER, August 27, 2013, p. 24, https://www.hud.gov/sites/documents/
20394_CONPLAN_MANUAL.PDF.
25 24 C.F.R. §91.15(b).
26 24 C.F.R. §91.15(b)(1).
27 24 C.F.R. §91.520.
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Department of Housing and Urban Development Consolidated Plan: An Overview

documentation components and their relationship with the implementation of grant funded
activities.
Figure 2. Consolidated Plan Process Documentation Components

Source: Congressional Research Service Graphic based on HUD guidance materials.
Federal regulations allow for amendments to a grantee’s Consolidated Plan to reflect changes in
allocation priorities, distribution methods, planned activities, or beneficiaries.28
Consultation and Citizen Participation
The regulations governing the Consolidated Plan require grantees to elicit input from a range of
agencies, organizations, local leaders, and residents within the grantee’s jurisdiction.29 HUD
guidance indicates consultation and citizen participation are key to ensuring that diverse
perspectives and priorities are considered and incorporated throughout the course of planning and
implementation.30 For example, HUD notes that effective consultation and community
participation could contribute to enhanced interagency coordination, as well as identification of
additional funding sources to leverage with HUD grant funds, among other potential outcomes.31
Furthermore, HUD suggests that consultation and citizen participation generate qualitative data
that may aid in setting grantee priorities and validate or provide additional context to the

28 24 C.F.R. §91.505.
29 24 C.F.R. §§91.100, 91.105, 91.110, 91.115, and 91.401.
30 HUD, The eCon Planning Suite: A Desk Guide for Using IDIS to Prepare the Consolidated Plan, Annual Action
Plan, and CAPER/PER, August 27, 2013, pp. 24-25, https://www.hud.gov/sites/documents/
20394_CONPLAN_MANUAL.PDF.
31 HUD, The eCon Planning Suite: Citizen Participation and Consultation Toolkit, July 2014, p. 3,
https://www.hudexchange.info/sites/onecpd/assets/File/eCon-Planning-Suite-Citizen-Participation-Toolkit.pdf.
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Department of Housing and Urban Development Consolidated Plan: An Overview

quantitative analysis required in other portions of the Consolidated Plan.32 HUD grantees have
some flexibility in designing their consultation and participation processes, provided they meet
regulatory requirements. HUD has developed guidance on potential outreach, engagement, and
consultation strategies for grantees to consider (e.g., holding online forums or creating thematic
maps).33
Consultation
During the Consolidated Plan development process, grantees must consult with public and private
entities that have a stake in the provision of services covered by the plan. Specific consultation
requirements may vary by grantee type and program.
Local Government Grantees
Local government grantees are required by regulations to consult with the following types of
entities in developing their Consolidated Plans:
• public and private assisted housing agencies;
• public and private health services agencies;
• public and private social services agencies;
• community and regional representatives of protected classes;
• fair housing enforcement organizations;
• broadband service providers and organizations “engaged in narrowing
the digital divide”; and
• agencies responsible for management of “flood prone areas” and “public
land or water resources.”34
The regulations require that grantees consult with additional entities in completing certain
portions of the Consolidated Plan. For example, as it pertains to the homeless strategy, a grantee
must engage with Continuums of Care that operate within its jurisdiction (Continuums of Care
are local planning bodies that respond to the needs of people experiencing homelessness and
collaborate in applying for HUD grants). The regulations require additional consultation with
public and private agencies focused on needs of persons experiencing or at risk of
homelessness—related to housing, health, social services, victim services, employment, or
education. Grantees must also engage publicly funded institutions that could discharge
individuals into homelessness (e.g., health-care facilities), as well as business and civic leaders on
issues related to the homeless strategy in the Consolidated Plan.35
For parts of the Consolidated Plan related to lead-based paint hazards, grantees are required to
consult with state or local health and child welfare agencies.36 Regarding “priority non-housing
community development needs,” local grantees are required to communicate with adjacent

32 HUD, Consolidated Plan Data Quick Guide, April 2023, p. 3, https://files.hudexchange.info/resources/documents/
CDBG-Consolidated-Plan-Data-Quick-Guide.pdf.
33 For example, see HUD Exchange, eCon Planning Suite Citizen Participation and Consultation Toolkit,
https://www.hudexchange.info/programs/consolidated-plan/econ-planning-suite-citizen-participation-and-consultation-
toolkit/.
34 24 C.F.R. §91.100(a)(1).
35 24 C.F.R. §91.100(a)(2).
36 24 C.F.R. §91.100(a)(3).
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Department of Housing and Urban Development Consolidated Plan: An Overview

jurisdictions, and submit plans to the state.37 Furthermore, on interjurisdictional issues, grantees
are required to consult with adjacent units of local government and regional governmental
entities.38 Grantees are also required to consult with public housing agencies (PHAs) on their
needs, planned initiatives, and issues related to affirmatively furthering fair housing.39
Program-Specific Local Consultation
Grantees of certain programs are also required to consult with additional entities. For example,
the largest city in a metropolitan statistical area with HOPWA eligibility is required to consult on
the development of a metropolitan strategy related to needs of individuals with HIV/AIDS and
their families.40 ESG local grantees are required to consult with the Continuum of Care on a range
of topics including grant allocation priorities and performance evaluation and monitoring.41
State Grantees
During the consolidated planning process, State grantees are required to consult with the
following types of entities:
• public and private assisted housing agencies;
• public and private health services agencies; and
• public and private social and fair housing services agencies.42
Like local government grantees, state grantees must consult with each of the Continuums of Care
within the state, public and private agencies and publicly funded institutions that provide services
that may be relevant to the needs of the local homeless population, and business and civic
leaders.43 Regarding lead-based paint hazards, state grantees are also required to consult with
state or local health and child welfare agencies.44
Program-Specific State Consultation
State grantees of some specific HUD Community Planning and Development programs are
required to consult with stakeholders on certain program specific issues, as well. For example,
state CDBG grantees must consult with nonentitlement communities regarding the process for
distributing program funds. State ESG grantees, similar to local ESG grantees, are required to
consult with all Continuums of Care within the state regarding various aspects of the grants
management process.45

37 24 C.F.R. §91.100(a)(4). Under the Consolidated Plan regulations, CDBG entitlement cities are also required to
submit such plans to the county.
38 24 C.F.R. §91.100(a)(5).
39 24 C.F.R. §91.100(c).
40 24 C.F.R. §91.100(b).
41 24 C.F.R. §91.100(d).
42 24 C.F.R. §91.110(a).
43 24 C.F.R. §91.110(b).
44 24 C.F.R. §91.110(c).
45 24 C.F.R. §§91.110(d)-(e).
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Department of Housing and Urban Development Consolidated Plan: An Overview

Citizen Participation
Citizen participation is a required component of any grantee effort to develop or substantially
amend its Consolidated Plan, as well as for annual action plans and annual performance reports.
HUD regulations require grantees to develop, publish, and implement a citizen participation plan,
as a component of the Consolidated Plan process. Some specific requirements vary by grantee
type.46 According to HUD guidance, the citizen participation plan “sets forth the grantee’s
policies and procedures for citizen participation throughout the Consolidated Planning process.”47
The regulations require that the citizen participation plan enable and encourage input from all
residents, with particular focus on low- and moderate-income residents, throughout the
consolidated planning process. Grantees are also required to take necessary steps to encourage
participation from minority groups, non-English speaking residents, persons with disabilities,
institutions such as Continuums of Care, and PHAs.48
Grantees must make the Consolidated Plan, any Consolidated Plan amendments, and performance
reports available to the public, in a manner outlined in the citizen participation plan. Additionally,
the regulations require that grantees provide “reasonable and timely access” to records and related
materials pertaining to the Consolidated Plan and its implementation from the previous five years.
The citizen participation plan must also outline the process by which the grantee will handle
public complaints on the Consolidated Plan, amendments, or performance reports. At a minimum,
the regulations require that grantees provide a substantive written response within a timeframe
established in the citizen participation plan.49
Local Government Grantees
In addition to the core regulatory requirements for citizen participation, local government
grantees are required to hold at least two hearings annually, with at least one occurring prior to
publication of the Consolidated Plan, for comment. Issues to be addressed in the hearings include
housing and community development needs, proposed activities, affirmatively furthering fair
housing, and program performance. Any public meetings associated with the Consolidated Plan
process must meet federal accessibility and reasonable accommodation requirements.50
Additionally, local governments are required to provide technical assistance to groups
representing low- and moderate-income persons for the development of proposals for assistance,
if requested. The nature of this assistance may be determined by the grantee, and must be outlined
in the citizen participation plan.
Consortia
Consortia are subject to the same citizen participation requirements as local government grantees.
The citizen participation plan for consortia with multiple CDBG entitlement communities must
provide for facilitation of public input in each of the communities.51

46 For local governments, see 24 C.F.R. §91.105; for states, see 24 C.F.R. §91.115; and for HOME consortia, see 24
C.F.R. §91.401.
47 HUD, The eCon Planning Suite: Citizen Participation and Consultation Toolkit, 2014, p. 6,
https://www.hudexchange.info/sites/onecpd/assets/File/eCon-Planning-Suite-Citizen-Participation-Toolkit.pdf.
48 See 24 C.F.R. §§91.105(a)(2), 91.115(a), and 24 C.F.R. §91.401.
49 CDBG grantees are required to respond within 15 working days, when practicable.
50 For applicable requirements, see 24 C.F.R. §§8 and 35-36.
51 24 C.F.R. §91.401.
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Department of Housing and Urban Development Consolidated Plan: An Overview

State Grantees
The regulations require that state CDBG grantees include, in their citizen participation plans,
public participation requirements with which nonentitlement communities must comply.
Contents of the Consolidated Plan
The Consolidated Plan process requires several action items that range from collecting
information and data about the grantee’s jurisdiction (Homeless and Housing Needs Assessment
and Housing Market Analysis), to planning for use of federal funds (the Strategic Plan), and
reporting on activities (the Annual Action Plan). Each of these components may have elements
that address the same issue area from one stage to the next. However, each component pertains to
a particular stage in the planning process.
Housing and Homeless Needs Assessment
State and local grantees must submit a housing and homeless needs assessment as part of the
Consolidated Plan.52 HOME program consortia are to follow the regulations for local
governments, but submit a plan for the entire consortia.53 Each grantee must provide a housing
needs assessment that estimates the need for a range of households over the next five-year period,
with separate analyses of people experiencing homelessness and other vulnerable populations.
HUD provides Census data for grantees to use, which grantees can update using data from locally
conducted studies or other reliable data sources. Aspects of the Housing and Homeless Needs
Assessment are incorporated into other components of the Consolidated Plan.
Need for Housing Assistance: Grantees are to assess the number and types of families in need of
housing assistance. The analysis is to occur for a range of families broken out by income, tenure
(owner vs. renter), and household type as specified in the regulations. For each category of
family, grantees are to report on the number that are cost burdened, are living in overcrowded
housing, and who live in substandard housing.
Specifically, the family categories enumerated in the regulations are: those with incomes ranging
from extremely low- to middle-income; renters and owners; large families and single person-
households; people who are elderly or have disabilities; people living with HIV/AIDS; families
living in public housing as well as those on waiting lists for assisted housing; those fleeing
domestic violence; and families and individuals formerly experiencing homelessness who are
receiving rapid rehousing assistance that will soon come to an end.54
Grantees must also break out disproportionate housing need among racial and ethnic groups by
income compared to people in that income group as a whole.
Homeless Needs Assessment: Grantees are to report the number of people experiencing
homelessness based on data from HUD’s Homeless Management Information System (HMIS)
and Point-in-Time (PIT) counts.55 The data reported are to include people who are experiencing
sheltered and unsheltered homelessness and those living in rural areas.

52 For local governments, see 24 C.F.R. §91.205, and for states, see 24 C.F.R. §91.305.
53 24 C.F.R. §91.405.
54 Rapid rehousing is short- to medium-term rental assistance typically not in excess of 24 months.
55 HMIS and PIT count data are collected by states and communities and submitted to HUD for inclusion in Annual
Homeless Assessment Reports. For more information, see https://www.hudexchange.info/homelessness-assistance/
ahar/#2023-reports.
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Department of Housing and Urban Development Consolidated Plan: An Overview

The Consolidated Plan also requires that data be provided on the number of people experiencing
homelessness on a given night (from PIT count data), the number of people who are homeless
over the course of a year (from HMIS data), people who become newly homeless, and people
who exit homelessness, with each category broken out by certain family types and characteristics.
These include people experiencing chronic homelessness, families with children, veterans, and
youth. Grantees are also to include data on homelessness by race and ethnicity.
In addition to reporting on people experiencing homelessness, the plan should analyze the
housing need and characteristics of individuals and families who are “threatened by
homelessness.” The analysis should include housing characteristics that are associated with
housing instability and risk of homelessness.
Non-Homeless Special Needs Assessment: Grantees are also to estimate the number of people
who might need housing with supportive services. These populations include those who are
elderly, including frail elderly; people with disabilities, including behavioral health issues; people
living with HIV/AIDS; public housing residents; and any other groups that a grantee identifies.
Lead-Based Paint Hazards: Grantees must report on the number of housing units in their area
that are occupied by low- or moderate-income families and have lead-based paint hazards.56
HOPWA-Specific Reporting: Jurisdictions that receive HOPWA funds as the largest units of
local government within an MSA are to report the number of people living with HIV/AIDS and
their housing and supportive services needs within the entire MSA.
Housing Market Analysis
The Consolidated Plan includes a housing market analysis that describes housing conditions in
the jurisdiction.
Local Governments and Consortia
Local governments must include a housing market analysis that includes the following
information as part of their Consolidated Plan. For consortia, the housing markets analysis must
include the same information for the entire consortium, though it may also include conditions for
the individual communities that make up the consortium.57
General Characteristics: Grantees are to describe “significant characteristics of the
jurisdiction’s housing market.” This includes information on supply, demand, and the condition
and cost of housing, as well as the housing stock available to serve certain populations with
special needs. Other factors to be addressed include information on vacant or abandoned
properties and areas of concentrations of racial or ethnic minorities and/or low-income families
within the jurisdiction. Since January 1, 2018, plans are also required to describe (1) broadband
needs of housing occupied by low- and moderate-income households, and (2) the vulnerability of
housing occupied by low- and moderate-income households to increased natural hazard risks
associated with climate change.58
Public and assisted housing: Grantees are to identify the public housing developments and
number of public housing units in the jurisdiction, as well as provide certain information about

56 The term “lead-based paint hazard” is defined at 24 C.F.R. §35.86.
57 24 C.F.R. §91.410.
58 For CRS assistance on issues related to natural hazards, see CRS Report R46438, Natural Disasters and Hazards:
CRS Experts, coordinated by Lauren R. Stienstra and Peter Folger.
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Department of Housing and Urban Development Consolidated Plan: An Overview

those units and their condition. In addition, the plans are to include a description of the number of
housing units currently assisted by any federal, state, or local programs and the income levels and
types of families served by those units, as well as whether any of the units are expected to be lost
from the assisted housing stock.
Facilities, housing, and services for homeless persons: Grantees are to provide a brief
inventory of facilities, housing, and services for homeless people in the jurisdiction, including
certain categories of homeless people. The inventory is to include both services targeted to
homeless people and mainstream services that are used to complement targeted services. In
contrast to the Housing and Homeless Needs Assessment, this element of the Housing Market
Analysis focuses on the jurisdiction’s facilities and services for those who are homeless, rather
than the number of people who are homeless.
Special need facilities and services: To the extent information is available, grantees are to
describe facilities and services for people who are not homeless, but require supportive housing.
It is also to describe programs to ensure that people returning from mental or physical health
institutions receive appropriate supportive housing.
Barriers to affordable housing: Grantees are to describe whether public policies, and the
jurisdiction’s policies in particular, affect the cost of housing or incentives to invest in affordable
housing in the jurisdiction. Such policies include “tax policies affecting land and other property,
land use controls, zoning ordinances, building codes, fees and charges, growth limits, and policies
that affect the return on residential investment.”
States
State governments submitting Consolidated Plans are required to include many of the same topics
as localities in their plans; however, some of the topics required of local governments do not
apply to state governments. Like local governments, state governments are to provide information
on general characteristics, including supply, demand, condition, and cost of housing, and
broadband needs and natural hazards (they are not required to include the information on vacant
or abandoned properties or concentrated areas of racial or ethnic minorities or low-income
families). States are not required to include information on public and assisted housing, but they
are required to include descriptions of facilities, housing, and services for homeless persons,
special need facilities and services, and barriers to affordable housing.
Strategic Plan
In the strategic plan portion of the Consolidated Plan, grantees are to describe their priorities for
how they will use the grant funds they receive.59
Local Governments
General: For certain specified categories of activities—affordable housing, public housing,
homelessness, other special needs, and non-housing community development—–the plan must
indicate the grantee’s priorities for allocating funds geographically and among activities. It must
also describe its rationale for each allocation priority, identify obstacles to meeting underserved
needs, and summarize objectives and how funds will be used, with measurable proposed
accomplishments or outcomes.

59 For strategic plan requirements that apply to local government grantees, see 24 C.F.R. §91.215; for state grantees, see
24 C.F.R. §91.315; and for consortia, see 24 C.F.R. §91.415.
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Department of Housing and Urban Development Consolidated Plan: An Overview

Affordable Housing: The grantee is to describe how the jurisdiction’s housing market conditions
and the housing needs of specified populations informed the decisions on its priorities for how to
use program funds. If the jurisdiction plans to use HOME funds for tenant-based rental assistance,
it must describe the circumstances that led the jurisdiction to choose to use funds for that purpose.
The grantee is also to list its specific objectives and proposed accomplishments, including
estimated numbers of how many households at different income levels will receive affordable
housing.
Public Housing: The grantee is to describe how the plan will address the needs of public
housing, including certain specified needs (increasing the number of accessible units, where
applicable; encouraging public housing residents’ participation in management and
homeownership, and, if a public housing agency is designated as “troubled,” assistance in
removing the troubled designation).
Homelessness: The grantee is to describe its strategy for reducing and ending homelessness
through outreach, emergency shelter and transitional housing needs, helping homeless persons
transition to permanent housing and living independently, and helping low-income households
avoid becoming homeless.
Other Special Needs: The grantee is to describe the need for housing and supportive services
among populations that, while not homeless, may have a need for supportive housing, such as the
elderly, people with disabilities, people with alcohol or drug addictions, people living with
HIV/AIDS, and public housing residents. If the grantee plans to use HOME funds to provide
tenant-based rental assistance to any of these populations, it must describe the housing market
conditions that informed that decision.
Non-housing Community Development Plan: Grantees seeking CDBG funds are to specify
their priority non-housing community development needs for each category of eligible CDBG
activities. They are also to specify both short-term and long-term community development
objectives.
Neighborhood Revitalization: Grantees are “encouraged to identify locally designated areas
where geographically targeted revitalization efforts are carried out through multiple activities in a
concentrated and coordinated manner.” With HUD’s approval, a grantee can also choose to carry
out a neighborhood revitalization strategy that includes economic empowerment of low-income
residents in one or more areas. Grantees carrying out such a HUD-approved neighborhood
revitalization strategy can gain more flexibility in the uses of CDBG funds in those areas.60
Barriers to Affordable Housing: As described above, the Housing Market Analysis section of
the Consolidated Plan is to describe any policies that may present barriers to affordable housing.
In the strategic plan, the grantee is to describe its strategy for removing the identified barriers to
affordable housing or to improve any negative effects stemming from those barriers.
Lead-Based Paint Hazards: The grantee is to describe both proposed actions and actions that it
is taking to reduce lead-based paint hazards and to increase access to housing that is free of such
hazards. It must describe how its plan for reducing lead-based paint hazards is related to the
extent of lead poisoning and lead hazards and how its plan for reducing such hazards will be
integrated into its housing policies and programs.
Anti-Poverty Strategy: The grantee is to concisely summarize its goals and its programs and
policies to reduce the number of families in poverty. It must also describe how its goals,
programs, and policies for producing or preserving affordable housing will be coordinated with

60 See 24 C.F.R. §§570.208(d)(5) and 570.483(e)(5).
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Department of Housing and Urban Development Consolidated Plan: An Overview

other programs and services and how they will reduce the number of families in poverty,
considering factors over which the grantee has control.
Institutional Structure: The local government is to concisely describe the institutional structure,
including both private and public organizations, through which the jurisdiction will carry out its
plan. It must also assess “strengths and gaps” in that delivery system and describe how the
jurisdiction will overcome gaps.
Coordination: Grantees are to summarize their activities to enhance coordination among the
Continuum of Care, public and assisted housing providers, and private and governmental health,
mental health, and service agencies, including the jurisdiction’s efforts to coordinate housing and
services for those who are homeless or were recently homeless. The grantee must also describe
“means of cooperation and coordination” among the state and local governments in the
metropolitan area in implementing the Consolidated Plan. The grantee is also to describe efforts
to enhance coordination with private industry, businesses, developers, and social services
agencies related to economic development.
Consortia
In general, consortia submit the same information as local governments for the strategic plan.
Consortia do not need to submit a non-housing Community Development Plan, but if CDBG
entitlement communities are part of the consortium, the Consolidated Plan must include those
entitlement communities’ non-housing Community Development Plans. In addition, the
consortium is to describe its priorities for allocating housing funding geographically throughout
the consortium, including CDBG and ESG funding, if applicable.
States
States are required to address the same topics as local governments and consortia in their strategic
plans, although there can be some differences in the specific information required. In addition,
states are also to address their strategy to coordinate the Low-Income Housing Tax Credit
(LIHTC) with the development of affordable housing for low- and moderate-income families.
Action Plan
Grantees submit action plans annually, providing an overview of planned activities related to the
priorities and goals outlined in their strategic plans, prior to each program year in the
Consolidated Plan period.61 The action plan expands on grantee assessments of needs, available
resources, and priorities, by describing specific goals and planned activities for the subsequent
program year. The required elements of the action plan vary by grantee type. 62

61 HUD, Using IDIS to Prepare the Consolidated Plan, Annual Action Plan, and CAPER/PER, June 2021, p. 51,
https://www.hud.gov/sites/dfiles/CPD/documents/Non-State-Certifications.pdf.
62 For local government action plan requirements, see 24 C.F.R. §91.220; for state requirements, see 24 C.F.R.
§91.320; and for consortia, see 24 C.F.R. §91.420.
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Department of Housing and Urban Development Consolidated Plan: An Overview

Local Governments
As part of the action plan, local government grantees are required to submit the Application for
Federal Assistance Standard Form 424 and an executive summary, in addition to the following
elements:63
Resources and Objectives: The action plan is to describe the federal, state, local, and private
resources available to address priorities identified in the Consolidated Plan process. Jurisdictions
must also summarize the annual objectives they plan to achieve in the next program year.
Activities to be Undertaken: Grantees must include a description of planned activities related to
priority objectives, with an estimate of beneficiaries and projected date of activity completion.
Outcome Measures: In the action plan, jurisdictions are required to outline how outcomes of the
planned activities will be measured.
Geographic Distribution: Grantees must describe the geographic areas to which program funds
will be targeted, with an explanation of the geographic prioritization.
Affordable Housing: The action plan must outline annual goals for the provision of affordable
housing assistance, with specific estimates on homeless, non-homeless, and special needs
households. Grantees must also outline the types of affordable housing activities, such as the
provision of rental assistance, development of new units, rehabilitation of existing units, and
acquisition.64
Public Housing: Grantees are required to list planned activities related to local public housing
needs and efforts to strengthen engagement and homeownership among public housing
residents.65
Homeless and Special Needs Activities: Grantees must include a description of one-year goals
related to homeless services including outreach, emergency shelter and transitional housing,
transitional housing-related services, and homeless prevention services.
Barriers to Affordable Housing: Grantees are required to include yearly plans to eliminate or
mitigate barriers to the development and preservation of affordable housing (e.g., restrictive
zoning ordinances).
Other Actions: Action plans must also discuss planned one-year efforts related to issues
including underserved needs, affordable housing, lead-based paint hazards, poverty reduction,
and enhanced coordination among public and private housing and social service agencies.
Program-Specific Requirements: Each of the five HUD programs covered by the Consolidated
Plan are subject to additional annual action plan reporting requirements.66

63 For information on the Standard Form 424, see HUD, HUD Form SF-424, 2022, https://www.hudexchange.info/
resource/306/hud-form-sf424/.
64 The regulatory definitions for affordable rental housing and affordable homeownership can be found at 24 C.F.R.
§§92.252 and 92.254, respectively.
65 Jurisdictions with public housing agencies deemed by HUD to be “troubled” must also report on efforts to improve
their status.
66 For local government program-specific annual action plan requirements, see 24 C.F.R. §91.220(l); for state
government requirements, see 24 C.F.R. §91.320(k); for consortia requirements, see 24 C.F.R. §91.425.
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link to page 18 Department of Housing and Urban Development Consolidated Plan: An Overview

States and Consortia
State grantees are required to submit action plans with broadly similar elements to those required
for local government grantees. Unlike local grantees, states are not required to include planned
activities related to local public housing needs and initiatives.
HUD regulations require consortia to submit the Federal Assistance Standard Form 424 and a
description of resources and activities as part of their action plans.
General Certifications
Each state and local grantee jurisdiction, as well as consortia, must make certain certifications as
part of the Consolidated Plan.67
Affirmatively Furthering Fair Housing: Grantees must certify that they will affirmatively
further fair housing (AFFH). The Fair Housing Act requires HUD to administer its programs in a
manner to affirmatively further fair housing.68 HUD, through both guidance and regulation, has
required formula grantees under the CDBG, HOME, HOPWA, and ESG programs to go through
a process to comply with the AFFH requirement.69 The process is separate from the consolidated
planning process, and has changed over recent presidential administrations. Most recently, on
February 9, 2023, the Biden Administration published a proposed AFFH rule in the Federal
Register.70
Anti-Displacement and Relocation Plan: Grantees must certify that they have a plan to prevent
displacement of residents due to activities involving CDBG and HOME funds. Regulations
governing both programs require that grantees issue a Residential Anti-Displacement and
Relocation Assistance Plan that complies with HUD regulations under the Uniform Relocation
Assistance and Real Property Acquisition Policies Act of 1970 (Uniform Relocation Act).71
Consolidated Plans are to describe steps that will be taken to minimize displacement and provide
for relocation assistance and for replacement of low-income housing units that might be
demolished or converted to another use.72
Anti-Lobbying: Grantees must certify that they are in compliance with HUD anti-lobbying
regulations.73
Legal Authority: Grantees must certify that the Consolidated Plan is authorized under state or
local law and that they have the authority to operate the formula grant programs for which they
are eligible.
Consistency with Strategic Plan: Grantees are to certify that the activities they undertake with
program funds will be consistent with the Strategic Plan (described earlier under the “Strategic

67 See 24 C.F.R. §91.225(a) for local governments and 24 C.F.R. §91.325(a) for state governments.
68 42 U.S.C. §3608(e)(5).
69 For more information, see CRS Report R44557, The Fair Housing Act: HUD Oversight, Programs, and Activities.
70 U.S. Department of Housing and Urban Development, “Affirmatively Furthering Fair Housing,” 88 Federal Register
8516, February 9, 2023, https://www.federalregister.gov/documents/2023/02/09/2023-00625/affirmatively-furthering-
fair-housing.
71 For CDBG, see 24 C.F.R. §570.606 and for HOME, see 24 C.F.R. §92.353.
72 24 C.F.R. § 42.325. More information is also available at U.S. Department of Housing and Urban Development,
HUD Handbook 1378.0, Tenant Assistance, Relocation and Real Property Acquisition Handbook,
https://www.hud.gov/program_offices/administration/hudclips/handbooks/cpd/13780.
73 Anti-lobbying regulations are at 24 C.F.R. §§87.100 et seq.
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link to page 18 Department of Housing and Urban Development Consolidated Plan: An Overview

Plan ” heading). In addition, HOPWA grantees that are units of local government are to submit
certifications from all localities within the MSA where they administer funds.74
Acquisition and Relocation: The Uniform Relocation Act has general regulations that apply to
federal agencies as well as projects receiving federal financial assistance in certain
circumstances.75 Grantees must certify compliance with these regulations regarding acquisition of
real property and relocation of persons who have been displaced.
Section 3: Section 3 of the Housing and Urban Development Act of 1968 (P.L. 90-448, as
amended) is meant to provide employment and training opportunities for low- and very low-
income persons, particularly those residing in assisted housing. The law applies to grant
recipients of HUD housing and community development construction or rehabilitation funds that
exceed certain thresholds.76 Grantees must certify that they will comply with the requirements of
Section 3.
Program-Specific Certifications
Community Development Block Grant
CDBG grantees submit certifications related to planning, financial, and legal aspects of program
administration.77 The Consolidated Plan regulations require that local governments and states
certify the following related to program planning:78
• compliance with the citizen participation plan;79 and
• identification of community development and housing needs and
establishment of short- and long-term community development
objectives.80
CDBG grantees must also make the following certifications regarding CDBG expenditures:
• they meet the program’s national objectives;81
• they principally benefit low- and moderate-income families, with at least
70% of program funds, during a one-, two-, or three-year period; and
• the jurisdiction will not seek to recoup capital costs through assessments
against low- and moderate-income owned or occupied properties, with
certain exceptions.
CDBG grantees must also certify adoption of the following legal policies:

74 24 C.F.R. §91.225(a)(5).
75 49 C.F.R. §§24.1 et seq.
76 12 U.S.C. §1701u and 24 C.F.R. §75.3. The law also applies to Public and Indian Housing Authorities.
77 24 C.F.R. §§91.225(b) and 91.325(b).
78 Pursuant to 24 C.F.R. §91.425, CDBG entitlement communities that are members of consortia are required to submit
the applicable certifications for local government grantees outlined in 24 C.F.R. §91.225.
79 State CDBG grantees are also required to make certifications regarding consultation with local governments.
80 Local jurisdictions are also required to certify adherence to an active HUD-approved Consolidated Plan.
81 For more information on CDBG National Objectives, see 24 C.F.R. §570.200.
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Department of Housing and Urban Development Consolidated Plan: An Overview

• prohibition of the use of excessive force by law enforcement agencies
within its jurisdiction against any individuals engaged in non-violent
civil rights demonstration;
• enforcement of laws against physically barring entrance to and exit from
non-violent civil rights demonstrations;
• compliance with anti-discrimination laws;82 and
• compliance with any applicable laws.83
HOME Investment Partnerships Program
Grantees that receive HOME funds must make the following certifications:84
• If a grantee plans to use HOME funds for tenant-based rental assistance, a
certification that rental-based assistance is an essential element of the
jurisdiction’s Consolidated Plan.
• A certification that it is using, and will use, HOME funds for eligible activities
and costs, and that it is not using, and will not use, HOME funds for prohibited
activities.
• A certification that, before it commits funds to a project, it will evaluate the
project in accordance with adopted guidelines and not invest any more HOME
funds in combination with other federal assistance than is necessary to provide
affordable housing.
Emergency Solutions Grant
States and localities that receive ESG must make certifications about emergency shelters for
which they receive funding.85
• If recipients use ESG funds for rehabilitation or conversion of a structure
to an emergency shelter and the costs exceed 75% of the property’s post-
rehabilitation/conversion value, then the recipient must operate the
property as a shelter for at least 10 years. In other cases, recipients must
certify that the property will operate as a shelter for at least three years.
However, regardless of renovation or conversion costs, if a recipient uses
ESG funds for shelter operating costs or street outreach services (based
at the shelter), they must continue operating the property as a shelter
while using those funds (as long as the same population or geographic
area continues to be served).
• Renovated shelters must be safe and sanitary.
• To the extent practicable, ESG recipients are to employ people
experiencing homelessness in constructing or renovating and operating

82 Specifically, the certification applies to title VI of the Civil Rights Act of 1964 (42 U.S.C. §2000d), the Fair Housing
Act (42 U.S.C. §§3601-3619), and implementing regulations.
83 Local governments must also certify compliance with lead-based paint procedures.
84 24 C.F.R. §§91.225(d), 91.325(d), and 91.425(a)(2).
85 24 C.F.R. §91.325(c) and 24 C.F.R. §91.225(c).
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Department of Housing and Urban Development Consolidated Plan: An Overview

ESG program facilities, including providing services to people living in
shelters.
Other required certifications by states and localities include assisting people experiencing
homelessness with obtaining permanent housing and supportive services; developing protocols to
prevent people who are leaving institutions from being discharged into homelessness;
establishing procedures to protect confidential information of clients who receive services related
to family violence; and obtaining matching funds.
Housing Opportunities for Persons with AIDS
States and MSAs that receive HOPWA funds must certify that any building that is purchased,
renovated, converted, or leased with HOPWA funds will operate in its capacity serving clients for
at least 10 years.86 If HOPWA funds were only used for “non-substantial” rehabilitation or repair,
then the property must be used for at least three years.
Both recipients must also certify that funds are only used to meet “urgent needs” not being met by
other public or private funds.
Housing Trust Fund
No program-specific certifications apply to the Housing Trust Fund.
Consolidated Annual Performance and Evaluation
Report
The regulations require grantees to submit annual performance reports, which are referred to as
the Consolidated Annual Performance and Evaluation Report (CAPER).87 In the reports, grantees
provide information about the progress they have made toward the goals in their Consolidated
Plan. The regulations require that certain specific information be provided, as well as any
additional information that reflects a grantee’s goals.
General Information: The regulations require grantees to provide information about the
resources made available to pursue the goals of the Consolidated Plan, the investments made, and
the locations of the investments. Grantees are to include the number of people assisted through
each investment, as well as their race and ethnicity. The report is also to describe actions taken to
affirmatively further fair housing as well as other actions that a grantee proposed to take in its
Consolidated Plan.
Affordable Housing: The report is to include a grantee’s progress in meeting affordable housing
needs, including families assisted and their income levels.
Homelessness: Grantees are to report about progress toward preventing and ending
homelessness. Specific information that is to be included are outreach efforts and interventions
through emergency shelter and transitional housing. Grantees are also to describe how they help
families transition to permanent housing and reduce the period of time that people spend
experiencing homelessness and prevent returns to homelessness. The report also includes a

86 24 C.F.R. §91.325(e) and 24 C.F.R. §91.225(e).
87 24 C.F.R. §91.520.
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Department of Housing and Urban Development Consolidated Plan: An Overview

description of homelessness prevention efforts, including those exiting institutions and systems of
care (such as hospitals, jails, prisons, and the foster care system).
Program-Specific Information: For each program for which they receive funding, grantees must
provide certain information, including the following:
• CDBG—a description of the way in which funds were used, as well as
the number of families assisted, broken out by income and family size.
• HOME—results of housing inspections of properties assisted with
HOME funds; assessment of affirmative marketing efforts, including to
minority- and women-owned businesses; use of program income;
projects and tenant characteristics; and emergency transfers that were
requested pursuant to the Violence Against Women Act (VAWA).
• HOPWA—the number of individuals assisted and type of assistance
provided and emergency transfer requests made pursuant to VAWA.
• ESG—number of persons assisted and the type of assistance provided;
program outcomes; and emergency transfer requests made pursuant to
VAWA.
• HTF—the accomplishments of the HTF; compliance with the HTF
allocation plan; and emergency transfer requests made pursuant to
VAWA.
HUD evaluates the CAPERs to determine if they are satisfactory. If a report is not submitted or is
not satisfactory, HUD may suspend funding or may withdraw and reallocate funding.88
HUD Review and Monitoring
HUD reviews Consolidated Plans of all grantees to ensure that they satisfy certain specific
requirements.89 If HUD does not disapprove a plan, it is deemed accepted within 45 days of
submission. HUD may disapprove part or all of a plan if
• It is inconsistent with the purposes of the Cranston-Gonzalez National
Affordable Housing Act (P.L. 101-625).90
• Certifications related to the CDBG program are unsatisfactory.
• It is substantially incomplete. Examples of incomplete plans identified in
the regulations are those:
• developed without citizen participation or collaboration;
• that do not fulfill required regulatory elements of the Consolidated
Plan;

88 24 C.F.R. §91.520(i).
89 24 C.F.R. §91.500.
90 The purposes of the Cranston-Gonzalez National Affordable Housing Act (P.L. 101-625) are helping families save
for a down payment, preserving existing assisted housing units, extending and strengthening partnerships for the
production of affordable housing, expanding federal rental assistance, and increasing the supply of supportive housing.
42 U.S.C. §12703.
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• containing inaccurate certifications (see “Program-Specific
Certifications”);91 and
• that do not make provisions for assisting a public housing agency
designated as “troubled.”
If HUD disapproves a plan, it must give reasons in writing, as well as actions a jurisdiction can
take to gain approval. A jurisdiction has 45 days to submit a revised plan to HUD.
Discussion
To differing degrees, the formula grant programs discussed in this report provide flexibility to
state or local governments to use federal funds in the way that best meets their needs, within
federal parameters set by statute and regulation. The consolidated planning process provides an
opportunity for communities to assess their particular housing and community development
needs, prioritize uses of HUD funds, and involve the public and other relevant entities in the
planning process. This process can foster the coordination of housing resources to address priority
needs and promote more efficient and effective use of program funds. The Consolidated Plan also
allows for some federal oversight of how funds are used, and can act as a federal policy lever to
induce communities to consider certain federal priorities in the development of their plans.
However, if planning requirements are too burdensome, it may limit the ability of some
communities to realize the full potential of the consolidated planning process.
Congress may have interest in changes to the Consolidated Plan’s contents or processes based on
the extent to which the consolidated planning process appears to be meeting its goals. At times,
Congress or HUD have expanded, or sought to expand, the types of information or level of detail
provided in the Consolidated Plan. HUD has also taken steps that could address potential capacity
concerns for grantees in developing the Consolidated Plan and for the agency in assessing grantee
needs. Other federal efforts have sought to enhance regional and interjurisdictional coordination
as it pertains to plans and processes facilitated by other federal agencies.
Consolidated Plan Modifications
The Consolidated Plan is a federal policy lever that Congress or HUD can use to influence the
factors that state and local governments consider when planning the uses of HUD program funds.
As such, there may be a tension between the goals of local control over the uses of funding from
these HUD programs and federal policy objectives. Modifications to the Consolidated Plan to
direct communities to consider certain housing policy priorities can increase awareness of and
responses to certain housing needs, but may also raise questions about the added administrative
burden on grantees or the overall effectiveness of including additional elements.
Over time, both Congress and HUD have proposed or implemented changes to the Consolidated
Plan to reflect certain priorities. Such changes have included requirements that the Consolidated
Plan consider broadband needs, natural hazards, and manufactured housing, while current
legislative proposals would require communities to report on their consideration of certain
specified regulatory and land-use policies. Other federal proposals have sought to modify or
clarify requirements related to public participation and performance measurement for certain
grantees.

91 Required certifications for local governments are at 24 C.F.R. §91.225, for states at 24 C.F.R. §91.325, and for
consortia at 24 C.F.R. §91.425.
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Department of Housing and Urban Development Consolidated Plan: An Overview

Expanded Requirements for Information to be Included in the Con Plan
In 2016, HUD issued a Final Rule that amended the Consolidated Plan regulations to require that
grantees include information on (1) access to broadband or high-speed internet, and (2) natural
hazards. Regarding broadband internet, the Final Rule requires that a grantee’s Consolidated Plan
include a description of “broadband access in housing occupied by low- and moderate-income
households.” Additionally, the rule requires the grantee to “consider providing broadband access”
for low-income households without such access. Regarding natural hazards, the Final Rule
establishes a requirement that the Consolidated Plan include a consideration of natural hazard
resilience to be incorporated in development plans, with specific focus on impacts for low- and
moderate-income residents.92
Some Members of Congress have also sought to expand the required elements or level of detail
provided by grantees on a range of policy issues and practices. For example, in the 116th
Congress, the HUD Manufactured Housing Modernization Act of 2019 (S. 1804 and H.R. 926)
would have directed HUD to issue guidelines for grantees related to including manufactured
homes in their Consolidated Plans. The explanatory statement accompanying the Further
Consolidated Appropriations Act, 2020 (P.L. 116-94) directed HUD to issue such guidelines.93
More recently, the Yes In My Backyard Act (S. 1688/ H.R. 3507 in the 118th Congress) would
require HUD to establish regulatory requirements for certain grantees to report on plans,
adoption, or potential benefits of specific types of land-use policies in the Consolidated Plan.
Similar bills have been introduced in previous Congresses. Currently, the HUD Consolidated Plan
includes more general requirements related to reporting on barriers to affordable housing.94
Citizen Participation
On January 10, 2024, HUD issued a proposed rule in the Federal Register that would—among
other changes—modify the Consolidated Plan citizen participation requirements for certain
grantees.95 The proposed rule would amend the local government and state grantee citizen
participation plan regulations to encourage broader outreach, including additional potential
methods of publicizing the Consolidated Plan. The proposed amendments would also require
grantees to ensure access to published materials for “persons with disabilities” and “limited
English proficient persons.”96
The proposed rule would also clarify the definition of the term “substantial amendment” in the
administration of CDBG funds. Specifically, the proposed amendment would clarify that adding a
new proposed CDBG activity not previously included in the Consolidated Plan or Action Plan
would qualify as a substantial amendment. Under HUD Consolidated Plan regulations, substantial
amendments initiate the public participation process prior to approval.97

92 HUD, “Modernizing HUD’s Consolidated Planning Process to Narrow the Digital Divide and Increase Resilience to
Natural Hazards,” 81 Federal Register 90997-91012, December 16, 2016.
93 “Explanatory Statement Submitted by Mrs. Lowey, Chairwoman of the House Committee on Appropriations
Regarding H.R. 1865, Further Consolidated Appropriations Act, 2020,” Congressional Record, daily edition, vol. 165,
(December 17, 2019), p. H11462.
94 See 24 C.F.R. §§91.210(e), 91.215(h), 91.220(j), 91.310(d), 91.315(h), and 91.320(i).
95 HUD, “Submission for Community Development Block Grant Program, Consolidated Plans, and Indian Community
Development Block Grant Program Changes,” 89 Federal Register 1746-1786, January 10, 2024.
96 Ibid., pp. 1766-1768.
97 Ibid., pp. 1766-1767.
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Department of Housing and Urban Development Consolidated Plan: An Overview

Data and Performance Measurement
The 2024 HUD proposed rule would also amend the Consolidated Plan regulations pertaining to
certain aspects of data collection and performance measurement. The proposed rule would
explicitly require state and local grantees to include information on manufactured housing in the
housing and homeless needs assessment and the housing market analysis, consistent with the
FY2020 Appropriations language.98 Additionally, the proposed rule would encourage local
grantees to prioritize funds for target areas with federal or state designations of economic distress,
and require CDBG entitlement grantees to include “quantitative, neighborhood-level outcome
goal accomplishments” in the CAPER.99
Grantee and HUD Capacity
The consolidated planning process involves tradeoffs between the content and robustness of the
planning and reporting requirements, on the one hand, and the capacity of grantees to carry out
the requirements in a meaningful way and for HUD to provide useful oversight, on the other.
Stakeholders sometimes raise concerns about the capacity of grantees to carry out the
consolidated planning process and the potential administrative burden involved, especially for
smaller grantees. HUD has taken steps over the years to attempt to make the process easier for
grantees. For example, HUD makes available custom tabulations of American Community
Survey (ACS) data from the Census Bureau, known as the CHAS data, that grantees can use in
preparing their Consolidated Plans.100 In addition, in 2012 HUD launched its eCon Planning Suite
to provide grantees with additional tools, including an online template and a mapping tool, to
improve their consolidated planning process.101 Nevertheless, aspects of the process may still be
time-consuming or otherwise pose difficulties for some grantees.102
In addition, although HUD assesses Consolidated Plans for compliance, it has indicated it does
not have capacity to carry out more detailed analyses that could provide broader insight on
common experiences and needs among grantees. In March 2023, HUD’s Office of Policy
Development and Research initiated a pilot project, pursuant to Executive Order 13960,
Promoting the Use of Trustworthy Artificial Intelligence in the Federal Government. Under the
pilot project, HUD has indicated it is exploring the use of AI capabilities that could assist agency
staff in reviewing Consolidated Plans for information that could support outreach, technical
assistance, and decisions related to program administration.103

98 Ibid., pp. 1767-1768.
99 Ibid.
100 See https://www.huduser.gov/portal/datasets/cp.html.
101 HUD, “HUD Launches Overhaul of Consolidated Planning Process,” press release, May 7, 2012,
https://archives.hud.gov/news/2012/pr12-077.cfm. For more information on the eCon Planning Suite, see
https://www.hudexchange.info/programs/consolidated-plan/econ-planning-suite/.
102 For example, the National League of Cities has argued that “The preparation of a Consolidated Plan is currently
complex and time-intensive for local governments” and that the federal government “must streamline the application
process and help with information gathering” and “not turn too quickly to punitive measures.” See National League of
Cities, 2024 National Municipal Policy and Resolutions, adopted at the 2023 City Summit, November 18, 2023, p. 114,
https://www.nlc.org/wp-content/uploads/2024/01/2024-NMP-1.16.2024.pdf.
103 HUD, AI Inventory, https://www.hud.gov/program_offices/cio/AI_Inventory.
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Department of Housing and Urban Development Consolidated Plan: An Overview

Regional Coordination
As noted above, the Consolidated Plan regulations require that grantees consult with a range of
public and private sector partners, as well as community stakeholders throughout the process.
HUD has also worked with certain federal agencies to encourage coordination of federal
assistance at the regional level. For example, HUD and the Economic Development
Administration (EDA) have issued guidance to encourage coordination among grantees in
developing the EDA Comprehensive Economic Development Strategy and the HUD
Consolidated Plan,104 pursuant to a 2016 memorandum of understanding (MOU) between the two
agencies.105 In a 2021 report on interagency coordination, the Government Accountability Office
(GAO) recommended that the agencies expand on the 2016 MOU, and seek opportunities to
include the Department of Agriculture. GAO also recommended that HUD and EDA “monitor
progress” related to the type of coordination encouraged in the joint guidance.106

104 HUD and EDA, Reducing Administrative Burden Through Aligned Planning, December 2017,
https://files.hudexchange.info/resources/documents/HUD-EDA-Reducing-Administrative-Burden-Through-Aligned-
Planning.pdf.
105 HUD and EDA, Memorandum of Understanding Between the United States Department of Housing and Urban
Development and the Economic Development Administration, Department of Commerce Regarding Integrated
Community and Economic Development Planning, 2016, https://www.hud.gov/sites/documents/
HUD_EDAPLANMOU_EDA.PDF.
106 U.S. Government Accountability Office, Economic Development: Opportunities Exist for Further Collaboration
among EDA, HUD, and USDA, GAO-21-579, July 2021, pp. 31-32, https://www.gao.gov/assets/d21579.pdf.
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Department of Housing and Urban Development Consolidated Plan: An Overview

Appendix. Terminology
The terminology around the Consolidated Plan may be cause for confusion. The Con Plan
consists of different components, some of which may themselves be separate reports. HUD
regulations describe the components as “Contents” of the Con Plan. Relevant components
include:
• Consolidated Plan (Con Plan): The Con Plan is a grantee’s analysis of
its housing affordability and community development needs. It includes
the Homeless and Housing Needs Assessment; Housing Market Analysis;
Strategic Plan; Action Plan, which, unlike the other components, is to be
submitted annually; and Certifications.
• Strategic Plan: The Strategic Plan is a portion of the Con Plan that
identifies priority needs and how to accomplish them. Grantees must
address needs in the areas of affordable housing, public housing,
homelessness, special needs, and community development.
• Action Plan: The Action Plan must be submitted every year. In it,
grantees describe the federal, state, local, and non-governmental
resources available and how they will be allocated to pursue the needs
and goals identified in the Con Plan.
• Consolidated Annual Performance and Evaluation Report
(CAPER): The CAPER is not technically considered one of the
components of the Con Plan. It is a separate reporting requirement that is
to occur annually. In the CAPER, grantees report their accomplishments
and progress made toward goals.
In 2012, HUD introduced an online system through which grantees input information required for
the consolidated planning process.
• Integrated Disbursement and Information System (IDIS): IDIS is a
software system for HUD formula grantees to report activities to HUD
and draw down their funds. In the context of the Consolidated Plan, the
software provides templates for the Consolidated Plan, Action Plan, and
CAPER.
• eCon Planning Suite: The suite consists of IDIS, the system through
which grantees submit the Consolidated Plan, and CPD Maps, which
help grantees compile data for the consolidated planning process.107

107 For more information, see https://www.hudexchange.info/programs/consolidated-plan/econ-planning-suite/.
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Department of Housing and Urban Development Consolidated Plan: An Overview

Author Information

Joseph V. Jaroscak, Coordinator
Libby Perl
Analyst in Economic Development Policy
Specialist in Housing Policy

Katie Jones

Analyst in Housing Policy

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