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HUD’s CPD Posts Guidance on Using FEMA, CDBG-CV, and ESG-CV for Non-Congregate Sheltering

HUD’s Office of Community Planning and Development (CPD) posted “Federal Funding Priority Order for Non-Congregate Shelter During COVID-19” on June 23. The document provides information to recipients of federal funds on how best to use specific federal resources for the operation of non-congregate sheltering (NCS) projects. Guidance focuses on funds from the FEMA Public Assistance (PA) Category B Emergency Protective Measures, Emergency Solutions Grant (ESG-CV), and Community Development Block Grant (CDBG-CV) programs.

NCS includes general services such as food, security, and other basic needs, which are eligible for reimbursement with FEMA PA Category B assistance. More specific wraparound services such as case management and housing navigation assistance are not eligible for FEMA reimbursement but may be funded with CDBG-CV or ESG-CV. Food, security, and other basic needs may be funded under CDBG-CV or ESG-CV once FEMA NCS assistance ends.

The document outlines a suggested order of assistance based on four stages of an NCS project. At the first stage, an initial request for and implementation of an NCS project, the document suggests tapping FEMA Public Assistance Category B, followed by CDBG-CV or ESG-CV. States and localities that need NCS to serve people experiencing homelessness who have tested positive for COVID-19, who are exhibiting symptoms or have been exposed to COVID-19, or who have a high risk of poor outcomes should work with their FEMA region to obtain approval to use FEMA PA assistance for NCS.

FEMA recommends provider organizations work closely with local and state partners to develop a project worksheet that meets the FEMA PA criteria for the initial 30 days of eligible non-congregate sheltering activities. This assistance is subject to the prevailing FEMA cost share of 75% FEMA/25% non-federal assistance. Communities may use CDBG-CV for cost share for an initial request or extensions.

The length of time FEMA non-congregate sheltering is needed will depend on local circumstances and will be decided in accordance with direction from appropriate health officials.

NCS supported with FEMA PA may not extend beyond a state or local public health order or the U.S. Department of Health and Human Services (HHS) Public Health Emergency for COVID-19. HHS declared a Public Health Emergency and renewed it on April 20 for an additional 90 days. FEMA may approve non-congregate sheltering in 30-day increments.

The second stage occurs when a FEMA-approved non-congregate shelter project ends. At this stage, a state or locality may continue funding NCS using ESG-CV or CDBG-CV.

The third stage entails transitioning people from NCS because those served only needed NCS for a brief period of time. At this stage, states and localities should transition people to another housing option rather than allow them to return to high-risk situations. States and localities may use ESG-CV funds for other forms of housing assistance, or if ESG-CVS is not available (not all localities automatically receive ESG) they may use CDBG-CV.

The fourth stage begins as FEMA PA ends. Once the FEMA PA emergency declaration and subsequent major declarations for COVID-19 incident periods ends, FEMA funding for NCS will cease. States and localities should transition people to other forms of housing assistance rather than allow them to return to high-risk locations. This transition may include continuing to support NCS or supporting congregate shelter using ESG-CV or CDBG-CV.

The document includes links to many FEMA and HUD resources.

“Federal Funding Priority Order for Non-Congregate Shelter During COVID-19” is at: https://bit.ly/3g78pgL

More information about using FEMA is on NLIHC’s COVID-19 & Housing/Homelessness website: https://nlihc.org/coronavirus-and-housing-homelessness and on page 6-44 of NLIHC’s 2020 Advocates’ Guide.

More information about CDBG is on page 8-3 of NLIHC’s 2020 Advocates’ Guide.

More information about ESG is on page 4-82 of NLIHC’s 2020 Advocates’ Guide.