NLIHC submitted comments in response to HUD’s Emergency Solutions Grant and Consolidated Plan Conforming Amendments Interim Rule on February 3. The interim rule was released on November 15 as part of the first set of regulations promulgated to implement the Homeless Emergency Assistance and Rapid Transition to Housing (HEARTH) Act of 2009. Also released on November 15 was a permanent rule on the definition of homelessness (see Memo, 11/18/2011).
The interim rule reflects changes made in the 2009 HEARTH Act, which replaced the Emergency Shelter Grant program with the Emergency Solutions Grant (ESG) program. The new ESG program includes an emphasis on homelessness prevention and rapid re-housing, and the rule incorporates many provisions from the temporary Homelessness Prevention and Rapid Re-Housing Program (HPRP).
NLIHC emphasized a few key points in its comments:
- ESG funds should be targeted to the households most in need of assistance. Given the difficulty in determining how prevention dollars should be targeted, NLIHC suggested that a greater emphasis be placed on rapid re-housing activities and that data be collected on households that enter shelter, to assist communities in better targeting prevention dollars.
- Policies should encourage housing stability once families are rapidly re-housed.
- Communities should be afforded flexibility when serving victims of domestic violence and their dependents through the ESG program.
NLIHC’s comments are available at: www.nlihc.org/sites/default/files/NLIHC_ESG_Comments_2-13-12.pdf