West Virginia
Performance
Improvement Clinic
November 2012
National Alliance to End Homelessness
IMPROVING POLICY | BUILDING CAPACITY | EDUCATING OPINION LEADERS
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The HEARTH Act
Timeline
 New Homeless Definitions Implemented December 2011
 Interim Regulations for Emergency Solutions Grants (ESG) posted December 2011
 Interim Regulations for Continuum of Care (Supportive Housing Program) published in July 2012
(We are in the public comment period! Plan to Comment)
HEARTH ACT: Emergency Solutions Grants (formerly Emergency Shelter Grant)
Summary and Analysis of the Interim ESG Rule
December 2011
On November 15, 2011, the U.S. Department of Housing and Urban Development (HUD) released an
interim rule for the new Emergency Solutions Grant program, which was officially published in the
Federal Register on December 5. The interim rule implements changes made by the Homeless
Emergency Assistance and Rapid Transition to Housing (HEARTH) Act of 2009. HUD also published a final
rule on “Defining Homeless” on December 5 and a draft regulation on the Homeless Management
Information System (HMIS) on December 9. Regulations governing the Rural Housing Stability Program
and the consolidated Continuum of Care (CoC) programs are expected in the coming months.
Overview and Rationale for Interim Rule
Congress passed the HEARTH Act in May 2009. Among other changes, the Act expanded the Emergency
Shelter Grant by adding rapid re-housing, more robust homelessness prevention, and HMIS as eligible
activities. The HEARTH Act also renamed the program as the Emergency Solutions Grant (ESG). It
emphasized the importance of helping people to quickly connect with or remain in permanent housing
after they experience a housing crisis or homelessness. HUD aims to help communities improve
integration with mainstream services, strengthen system-level coordination, and build on lessons
learned from years of practice and research to invest in proven solutions like rapid re-housing.
Normally, HUD publishes a proposed rule, accepts public comments, and uses that feedback to release a
final regulation that will go into effect. However, HUD has decided that it would be in the public’s best
interest to begin implementation of the new ESG program as quickly as possible. This requires the use of
an interim rule that will go into effect almost immediately, though HUD will still take public comments
into consideration before publishing a final rule.
While many federal program funding levels were reduced in fiscal year (FY) 2011, Congress specifically
provided additional funding for the new ESG program. HUD interprets this to mean that Congress
recognizes the need for homeless assistance and that the new ESG program can have an immediate
impact on helping people experiencing and at risk of homelessness.
Timing
The regulation will go into effect on January 4, 30 days after it was officially published in the Federal
Register.
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Individuals and organizations are encouraged to submit comments to HUD to provide feedback on
HUD’s interpretation of the HEARTH Act as it relates to the ESG program. Public comments are due
February 3. HUD will subsequently publish a final regulation on the new ESG program.
Definitions
The interim ESG rule identifies three categories of people who are “at risk of homelessness” and are
therefore eligible for homelessness prevention assistance. At-risk households include:
1. Individuals and families who have all three of the following characteristics:
o Have incomes below 30 percent of area median income; AND
o Have insufficient resources (i.e. family, friends, faith-based or social networks)
immediately available to attain housing stability and avoid entrance into an emergency
shelter or literal homelessness; AND
o Exhibit one or more qualifying risk factors (see below for details).
2. Children and youth who qualify as homeless under other federal statutes, including the
Runaway and Homeless Youth Act, Head Start Act, Violence Against Women Act, Public Health
Service Act, Food and Nutrition Act, or Child Nutrition Act; AND
3. Children and youth (and their parents/guardians who live with them) who qualify as homeless
under the Department of Education definition (Education for Homeless Children and Youth
section of the McKinney-Vento statute).
Qualifying risk factors under the first category of at-risk households include people who:
 Have moved frequently (2 or more times during the 60 days immediately prior to application for
assistance) because of economic reasons;
 Are living in the home of another because of economic hardship;
 Have been notified that their right to occupy their current housing or living situation will be
terminated;
 Live in a hotel or motel;
 Live in severely overcrowded housing;
 Are exiting an institution; or
 Otherwise live in housing that has characteristics associated with instability and an increased
risk of homelessness.
In addition, this interim rule clarifies the definition of chronic homelessness. Being chronically homeless
has involved having a disability and living in a safe haven, an emergency shelter, or a place not meant for
human habitation for a year or more continuously, or on at least four separate occasions over three
years. In this interim rule, HUD determines that a person must be homeless at least 15 days for it to
count as a distinct episode of homelessness.
Eligible Activities
The ESG rule allows ESG funds to be used for several components—street outreach, emergency shelter,
homelessness prevention, rapid re-housing, and HMIS— and the necessary administrative costs for
each.
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
Street Outreach and Emergency Shelter. The interim ESG rule adds to the list of eligible shelter
activities the costs of supplies and motel/hotel stays in certain cases, and it removes the limit on
staff costs.
To the extent possible, essential services for emergency shelter and street outreach under this
rule are the same as eligible costs for supportive services under the CoC program. HUD has done
this in order to facilitate coordination and improve understanding of requirements.

Homelessness Prevention and Rapid Re-Housing Assistance. ESG funds can be used for:
 Short-term (up to 3 months) and medium-term (up to 24 months) rental assistance; and
 Housing relocation and stabilization services.
Both prevention and rapid re-housing assistance can be provided for a short-term period of up
to 3 months, or for a medium-term period of between 3 and 24 months. Rental assistance can
include a one-time payment of up to 6 months of rent arrears. Other than rental arrears,
assistance cannot be provided to households simultaneously receiving rental assistance from
other public sources.
Homelessness prevention assistance is only eligible to the extent that it is necessary to help
program participants regain stability in their current housing or move into other permanent
housing and achieve stability there.
Recipients have broad discretion to decide the type, length, and depth of rental assistance
provided, as long as it does not exceed 24 months during any 3 year period. Program
participants must sign a lease with the housing owner, and the provider must sign a rental
assistance agreement with the housing owner.
Under the interim ESG rule, program participants’ eligibility, as well as the types and amounts of
assistance they receive, must be re-evaluated at least once every three months for prevention
assistance and at least once per year for rapid re-housing assistance.
As required under the HEARTH Act, the interim rule also allows rental assistance to be either
project-based or tenant-based. In order to ease the transition into permanent housing and
avoid forcing households to move when their project-based assistance ends, the interim rule
states that project-based assistance may be suspended, terminated, or transferred to another
unit upon a client exiting the program.
Under project-based assistance, the provider may sign a contract and pay up to the entire first
month’s rent, provided that a program participant signs a lease and moves into the unit prior to
the end of the first paid month. The lease must not condition occupancy to the provision of
rental assistance payments. The rental assistance agreement between the provider and the
housing owner must have an initial period of at least one year. HUD specifically requests
comments on how to best structure project-based short- and medium-term rental assistance so
as to avoid forcing program participants to move at the end of their assistance.
Eligible housing relocation and stabilization services include:
 Financial assistance costs, including rental application fees, security deposits, last
month’s rent, utility deposits, up to 24 months of utility payments, and moving costs
(including temporary storage costs of up to 3 months); and
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

Stabilization assistance costs, including housing search and placement, housing stability
case management, mediation, legal services, and credit repair.
HMIS. Under the HEARTH Act, all projects receiving funding under the ESG program must
participate in a Homeless Management Information System (HMIS). HUD published a proposed
rule1 on December 9 to establish the regulations to govern HMIS.
Administrative Costs
Under the HEARTH Act, the portion of ESG grants that can cover administrative costs is increased from 5
percent to 7.5 percent of a jurisdiction’s entire grant.
In FY 2011, HUD has divided the ESG grant into two allocations. The first allocation was released in
Summer 2011 under the old Emergency Shelter Grant. The second allocation2 was announced in
November 2011 in conjunction with the interim Emergency Solutions Grant rule. Under the first FY 2011
allocation, the old rules still applied, and communities could only use 5 percent of their ESG funds to
cover administrative costs. As a result, some communities may be able to spend more than 7.5 percent
of their second allocation of FY 2011 ESG funds for administrative costs. The total percent of the
combined first and second allocations put toward administrative costs cannot exceed 7.5 percent.
The rule clarifies that employee compensation and other overhead costs directly related to carrying out
the ESG program components are eligible costs of those activities and are not subject to the spending
limit for administrative costs.
Centralized or Coordinated Assessment
In its interim ESG rule, HUD explains that it expects to include in an upcoming proposed rule for the CoC
program a requirement for communities to develop and implement a centralized or coordinated
assessment system. This interim rule proposes that ESG recipients will be required to participate in this
system to initially assess the needs of each household seeking prevention or homeless assistance.
Regardless of which year’s funding is being used, ESG recipients will be required to implement this
provision, though not until a final CoC program rule has been published and the CoC has implemented
such an assessment system.
CoCs would design these systems based on local needs. It will be important for communities to develop
a common assessment tool for use throughout the community, though tools will vary from community
to community. Centralized or coordinated intake can take a number of forms, including:
 A central location(s) where individuals must present for homeless services;
 A 2-1-1 or other hotline that screens callers using the common assessment tool and connects
them to appropriate local providers;
 A “no wrong door” approach in which a household can present at any homeless service provider
in the area and be assessed and referred using the same tool;
 A specialized team of case workers that provide assessment services to providers within the
CoC; or
1
http://www.gpo.gov/fdsys/pkg/FR-2011-12-09/pdf/2011-31634.pdf
2
http://www.hudhre.info/index.cfm?do=viewResource&ResourceID=4518
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
A regional approach in which “hubs” are created within smaller geographic areas.
HUD requests comments from ESG-funded victim service providers on how to ensure that a coordinated
intake system does not increase risk for people fleeing domestic violence, dating violence, sexual
assault, or stalking. Each community will be required to develop a specific policy on how to address the
needs of households fleeing domestic violence.
HUD has included this proposed requirement for coordinated or centralized assessment based on
lessons from HPRP and the Rapid Re-Housing for Families Demonstration. Coordinated assessment helps
communities to match households with the most appropriate available resources to meet their needs,
improving system efficiency.
Case Management
The ESG interim rule specifies that program participants must meet at least monthly with a case
manager, who must develop an individualized permanent housing plan. Case managers must help
connect households with appropriate services and financial assistance through other public and private
homeless assistance and mainstream programs.
Housing stability case management can last no more than 30 days while the program participant seeks
permanent housing and no more than 24 months once in permanent housing. Eligible case management
activities include:
 Using the centralized or coordinated assessment system;
 Conducting an initial evaluation;
 Counseling;
 Developing, securing, and coordinating services and public benefits;
 Monitoring and evaluating program participant progress;
 Providing information and referrals to other providers;
 Developing an individualized housing and service plan; and
 Conducting re-evaluations.
Immediate Implementation of Prevention and Rapid Re-Housing Activities
HUD’s proposed rule will go into effect January 4, 2012. Communities have already received one
allocation of FY 2011 Emergency Shelter Grant resources, but they are receiving a second FY 2011 ESG
allocation. All funds under the second allocation must go toward newly-eligible activities, including
prevention, rapid re-housing, HMIS, and administration. No resources from the second FY 2011
allocation may be put toward street outreach or emergency shelter.
Communities can spend on traditional shelter and outreach activities the greater of either:
 60 percent of their total ESG grant; OR
 The amount of ESG dollars utilized for these activities in FY 2010.
In total, HUD is providing $250 million for ESG programs in FY 2011, including $160 million that was
released in Spring 2011 for traditional shelter and outreach activities. Because $160 million is slightly
more than 60 percent of the total national grant, the second of the above options is applicable to
communities in FY 2011. Therefore, in most cases, communities can spend on traditional shelter and
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outreach activities in FY 2011 only as much as they spent in FY 2010; all additional resources (the entire
amount of the second FY 2011 allocation) must be put toward the newly-expanded homelessness
prevention and rapid re-housing activities, including HMIS and administration.
Communities that wish to do so can reprogram a portion of their initial FY 2011 ESG installment from
shelter and outreach activities toward prevention and rapid re-housing. To do so, communities must
amend their Consolidated Plan in accordance with the ESG rule.
In future fiscal years, the entire ESG amount will be allocated at one time. However, communities still
must spend on traditional shelter and outreach activities no more than either 60 percent of the total
grant, or the amount spent on these activities in FY 2010, whichever is greater.
Changes to the Consolidated Plan
The HEARTH Act and Federal Strategic Plan to Prevent and End Homelessness both envision increased
collaboration between ESG programs, CoC programs, and other mainstream housing and services
programs. In this interim rule, CoCs must participate in the local Consolidated Plan process and evaluate
outcomes for ESG projects. In turn, ESG recipients must consult with CoCs about the allocation of ESG
funds and participation in HMIS.
The regulation requires a greater focus in Consolidated Plans on homeless people, especially chronically
homeless people, families with children, veterans and their families, and unaccompanied youth, as
outlined in the Federal Strategic Plan.
The interim rule also specifies that local jurisdictions must consult with publicly-funded institutions and
systems of care that may discharge people into homelessness and must make other changes to the
Consolidated Plan to ensure increased consistency between the Consolidated Plan and the CoC Plan.
These changes are intended to foster closer coordination between ESG and CoC programs, as well as
other mainstream housing and services programs.
Coordination with Other Systems and HUD Resources
The HEARTH Act requires that ESG recipients consult with CoCs in allocating funds for eligible activities,
developing performance standards, evaluating outcomes, and administering and operating HMIS.
ESG recipients are required, as much as possible, to coordinated ESG activities with other programs
targeted toward homeless people, as well as mainstream housing, health, social services, employment,
education, and youth programs for which homeless and at-risk families and individuals may be eligible.
Recipients should coordinate with, among many others, CoC, HUD-VASH, Education for Homeless
Children and Youth, Health Care for the Homeless, Runaway and Homeless Youth, Homeless Veterans
Reintegration, Section 8, Public Housing, HOME Investment Partnership, Workforce Investment Act, and
TANF programs. Both the Federal Strategic Plan and recent reports from Congress encourage HUD and
communities to maximize coordination among these targeted and mainstream programs.
HUD has tried to align these regulations with other mainstream programs, coordinating where possible
the ESG rule with Community Development Block Grant (CDBG), HOME, and Section 8 regulations.
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Where possible, HUD also aims to align the ESG program with the CoC and Rural Housing Stability
programs, to improve efficiency and coordination among the programs.
HEARTH ACT: Continuum of Care
Summary and Analysis of the Interim CoC Rule
August 2012
On July 31, 2012, the HUD published an interim rule in the Federal Register for the new consolidated
CoC program. The interim rule implements changes made by the HEARTH Act of 2009. Regulations
governing the Rural Housing Stability Program are expected in the coming months.
The regulations note that the purpose of the CoC is to:
 Promote community-wide goals to end homelessness;
 Provide funding to quickly re-house homeless people while minimizing trauma and dislocation;
 Promote access to and effective utilization of mainstream programs; and
 Optimize self-sufficiency among people experiencing homelessness.
The regulations reiterate in several places that children, unaccompanied youth, and families, as well as
individuals, are eligible for CoC programs as long as they meet other eligibility requirements.
Timing
The regulations went into effect on August 30, 30 days after they were officially published in the
Federal Register.
Individuals and organizations are encouraged to submit comments to HUD to provide feedback on
HUD’s interpretation of the HEARTH Act as it relates to the CoC program. Public comments are due
October 1. HUD will subsequently publish a final regulation on the consolidated CoC program.
Eligible Activities/Components
The interim regulations state that CoC funds may be used for the five program components listed below.
Administrative costs are eligible under each of the five components.
1. Permanent housing
 The program participant must be the tenant on a renewable lease with an initial term of at
least one year.
 Eligible types of permanent housing are:
o Permanent supportive housing for persons with disabilities; and
o Rapid re-housing (see below for more detail).
2. Transitional housing
 Program participants in transitional housing must have a lease that has a term of at least 1
month but no longer than 24 months and cannot be extended.
3. Supportive services only (SSO)
 SSO grants cover supportive services, including street outreach, to both sheltered and
unsheltered homeless persons to whom the recipient or subrecipient is not providing housing
assistance.
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4. HMIS
 An HMIS Lead may use CoC funds to lease or operate a structure in which HMIS is operated,
and for other eligible costs.
5. Homelessness prevention (limited cases only)
 The HEARTH Act increased the focus on homelessness prevention, though prevention
resources are intended to be available to communities primarily through the ESG program.
 Communities designated as high-performing communities (HPCs) may use CoC funds to
provide homelessness prevention assistance (housing relocation and stabilization services
and short- or medium-term rental assistance) to individuals and families at risk of
homelessness. Only HPCs are able to use CoC funds to serve people at risk of homelessness;
all other CoC funds must be used to serve people who are currently experiencing
homelessness.
The regulations are clear that all projects currently funded through the CoC are eligible for renewal.
Components of Rapid Re-Housing Assistance
In order to make rapid re-housing assistance consistent whether it is funded through the CoC program
or the ESG program, the interim CoC regulations make it clear that participants may receive short-term
(up to 3 months) or medium-term (up to 24 months) rental assistance and supportive services. However,
rapid re-housing assistance through the CoC program is not limited to the housing stabilization and
relocation services valid under ESG; instead, rapid re-housing funded through the CoC program can
include any of the services currently eligible through programs currently funded through the Shelter Plus
Care or Supportive Housing Program. CoCs may elect to limit the services available to program
participants in CoC-funded rapid re-housing programs to more closely match the services available
under ESG-funded rapid re-housing programs.
Under the interim regulation, rapid re-housing program participants must meet at least monthly with a
case manager. Participants must also be re-evaluated at least once per year to confirm that they still
lack the necessary resource and support networks to retain housing without rapid re-housing, and that
the amount and type of assistance being provided is still appropriate. In addition, supportive services
can be provided for up to 6 months after the rental assistance ends.
Supportive Services
The interim regulations note that a program may require clients to participate in supportive services, as
long as they are not disability-related services. If project’s main purpose is to provide substance use
treatment services, then clients can be required to take part in these services as a condition of program
participation. However, a program whose purpose is not providing substance use treatment may not
require participation in substance use treatment services. For example, a program may not require its
clients to participate in alcohol treatment unless its core mission is related to providing alcohol
treatment.
Supportive services that are provided must be necessary to assist program participants in obtaining and
maintaining housing. They must be made available for the duration of a client’s participation in a
permanent supportive housing or transitional housing program. They can be provided for up to 6
months after a program participant exits a rapid re-housing or transitional housing program.
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Serving Families and Children Defined as Homeless by a Different Federal Statute
Under the HEARTH Act, communities may use up to 10 percent of their CoC funds to serve families and
unaccompanied youth defined as homeless under other federal statutes. CoCs wishing to do so must
demonstrate in their application that using the funds for this purpose is of an equal or greater priority
than serving people defined as homeless by HUD and that it is equally or more cost-effective in meeting
the overall goals and objectives of the recipient’s plan for reducing the number of people experiencing
homelessness, the average length of time they remain homeless, and other key strategies for ending
homelessness.
CoCs whose most recent point-in-time count shows a rate of homelessness that is less than one-tenth of
one percent of the total population are not limited to using only 10 percent of their CoC funds to serve
this population.
High-Performing Communities
The HEARTH Act provides HUD with the authority to designate certain CoCs as high-performing
communities (HPCs). The interim regulations clarify that HUD can select up to 10 CoCs to designate as
HPCs for the year. Collaborative applicants can apply for the designation by demonstrating through
reliable data that the CoC meets all of the required standards for HPCs related to length of stay,
recidivism, HMIS coverage, and assistance to families and youth defined as homeless under other
federal statutes.
HPCs must show that:
 The mean length of stay in homelessness in the CoC is less than 20 days, or it has fallen by at
least 10 percent in the past year;
 Less than 5 percent of people leaving homelessness become homeless again within the next
2 years, or the percentage of people doing so has fallen by at least 20 percent in the past
year;
 The HMIS has both a bed coverage rate and service coverage rate of at least 80 percent; and
 If the CoC served families and youth defined as homeless under other federal statutes, 95
percent of those families did not become homeless again within 2 years of their assistance
ending, and 85 percent of them achieved independent living in permanent housing for at
least 2 years after assistance ended.
When a CoC has been designated as high-performing, the HEARTH Act provides that, in addition to
normally eligible uses of CoC funds, the HPC can use CoC funds for homelessness prevention in the form
of short- and medium-term rental assistance and housing relocation and stabilization services to people
at risk of homelessness.
Centralized or Coordinated Assessment System Access
HUD is requiring that all CoCs establish and operate a centralized or coordinated assessment system to
conduct an initial, comprehensive assessment of the housing and services needs for all people entering
the homeless assistance system. HUD notes that these systems should be designed in response to local
needs and conditions and should include use of a locally-designed, common assessment tool. CoCs are
required under the interim regulation to develop a specific policy on how the coordinated assessment
system will address the needs of people fleeing or attempting to flee domestic violence.
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In addition, CoCs will be required to develop and follow written standards for how they plan to
administer assistance through coordinated assessment. CoCs must develop standards for providing
assistance including:
 Evaluating eligibility for assistance;
 Prioritizing who receives transitional housing;
 Prioritizing who receives rapid re-housing;
 Determining what percentage or amount of rent people receiving rapid re-housing must pay;
 Prioritizing people for permanent supportive housing; and
 If designated as an HPC, prioritizing who receives homelessness prevention assistance.
Establishing a CoC Board
The regulations require that all CoCs establish a governing Board within two years of enactment of the
interim regulations. The Board must be representative of the subpopulations of homeless people within
the CoC’s geographic area, and there must be at least one homeless or formerly homeless individual on
the Board. Recipients and subrecipients of CoC funds will also be required to have at least one homeless
or formerly homeless person on their organizations’ Boards.
Changes to the Definition of Chronically Homeless
In its interim ESG regulations, HUD stated that it had determined that for a person to qualify as
chronically homeless by having been homeless on at least 4 separate occasions over 3 years, each
episode of homelessness must have lasted at least 15 days. In the interim CoC rule, however, HUD has
reconsidered this 15-day requirement and amends the regulations accordingly. The length of an episode
is once more up to communities to decide.
Unified Funding Agencies
The interim regulation establishes that CoCs can designate a collaborative applicant to become the
Unified Funding Agency (UFA) for the CoC. UFAs enter into a single contract with HUD for the provision
of CoC housing and services over the entire CoC geographic area, and then contact with subrecipients
throughout the geographic area for all CoC projects. UFAs are responsible for exercising fiscal control
and monitoring the accounting procedures of all subrecipients.
Administrative Costs and Match Requirements
A CoC may spend up to 3 percent of its final pro-rata need on administrative costs related to CoC
planning. Entities that are also UFAs may spend up to an additional 3 percent on administrative costs.
Under the HEARTH Act, the CoC must match all eligible funding costs, except for leasing costs, by no less
than a 25 percent cash or in-kind match.
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Definition of Homelessness/Eligibility
Summary of Changes Compared to Current Law
The following table summarizes the new definition of homelessness, compares it to the existing
definition, and summarizes the documentation requirements. Significant changes from the existing
definition are underlined.
CORE DEFINITION
Traditional HUD Definition
An individual or family who lacks a fixed,
regular, and adequate nighttime residence,
which includes a primary nighttime residence
of:
Place not designed for or ordinarily used as a
regular sleeping accommodation (including car,
park, abandoned building, bus/train station,
airport, or camping ground)
Publicly or privately operated shelter or
transitional housing, including a hotel or motel
paid for by government or charitable
organizations;
In addition, a person is considered homeless if
he or she is being discharged from an
institution where he or she has been a resident
for 30 days or less and the person resided in a
shelter or place not meant for human
habitation immediately prior to entering that
institution.
New Definition
An individual or family who lacks a fixed, regular,
and adequate nighttime residence, which includes a
primary nighttime residence of:
Place not designed for or ordinarily used as a regular
sleeping accommodation (including car, park,
abandoned building, bus/train station, airport, or
camping ground)
Publicly or privately operated shelter or transitional
housing, including a hotel or motel paid for by
government or charitable organizations;
In addition, a person is considered homeless if he or
she is being discharged from an institution where he
or she has been a resident for 90 days or less and
the person resided in a shelter (but not transitional
housing) or place not meant for human habitation
immediately prior to entering that institution.
Imminently Losing Primary Nighttime Residence
Traditional HUD Definition
New Definition
Individual or family is being evicted within 7
Individual or family is being evicted within 14 days
days from a private dwelling and:
from their primary nighttime residence and:
 No subsequent residence has been
 No subsequent residence has been identified;
identified; and
and
 The household lacks the resources or
 The household lacks the resources or support
support networks (i.e. family, friends,
networks (i.e. family, friends, faith-based or
faith-based or other social networks)
other social networks) needed to obtain
needed to obtain other permanent
other permanent housing.
housing.
 (Documentation required to show all 3
requirement exist)
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Persistent Housing Instability (At Imminent Risk)
Traditional HUD Definition
New Definition
People who experience persistent housing
Unaccompanied youth (less than 25 years of age) or
instability were not considered homeless.
family with children and youth with all of the
following characteristics;
2. Defined as homeless under other federal statutes
(for example the definition used by the Department
of Education) who do not otherwise qualify as
homeless under HUD’s definition; AND
3. Has not had a lease, ownership interest, or
occupancy agreement in permanent housing in the 60
days prior to applying for assistance; AND
4. Has moved two or more times in the 60 days
immediately prior to applying for assistance; AND
5. Has one or more of the following:
 chronic disabilities,
 chronic physical or mental health conditions
 substance addiction
 histories of domestic violence or childhood
abuse
 child with a disability
 two or more barriers to employment, which
include
 lack of a high school degree or GED
 illiteracy
 low English proficiency
 history of incarceration or detention for
criminal activity
 history of unstable employment
(Documentation required of the above)
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System Design Handout
There are four main areas to focus on when thinking about how your system should be designed. For each of these
focus areas, there are several change strategies that you can use to improve how well your system prevents and
ends homelessness. The change strategies are described in more detail on the Menu of Change Strategies
handout.
Change Strategies
Coordinated Assessment: A single or coordinated
system by which homeless people and those at risk
find and access shelter, housing and/or services.
Prevention targeting: Improving prevention
programs to better target people most likely to
become homeless by using system data, targeted
outreach methods, screening and greater program
flexibility.
Diversion: Program/approach that provides rapid
assessment and immediate assistance to prevent
shelter entry.
1.
Point of Access
Point of Access Checklist
Must haves
Options
✓
Uniform intake process
✓
Single or multiple points of entry
✓
Access to prevention/diversion resources
✓
physical location or virtual or both
✓
Ability to refer to shelter resources
✓
Housing barrier assessment
✓
Data collection
✓ Written standards for eligibility and
prioritization of ES, TH, PSH and RRH programs
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Exit Strategy
Change Strategies
Convert Transitional Housing: Modifying
transitional housing programs to provide other
forms of assistance, including rapid-rehousing,
transition- in-place, etc.
Expand Rapid Re-housing: Developing or
expanding programs that re-house families or
individuals as quickly as possible.
Convert Shelter to Rapid Re-housing: Shifting
traditional shelter resources to support rapid
rehousing programs.
Facilitating Exits from Permanent Housing:
Assisting tenants of permanent supportive
housing who no longer need intensive services to
move to other affordable (frequently subsidized)
housing and receive services in the community.
Example of options for Transitional Housing Conversion
Potential Models
•
•
•
•
•
Permanent Supportive Housing
Emergency/ Interim Housing
Transition in Place
Service Enriched Housing
Rapid Re-housing
Exit Strategy Checklist
Must haves
Options
✓
Rapid Re-housing
✓
Tiered Rapid Re-housing
✓
Support from shelter providers
✓
Transition in Place programs
✓
Permanent supportive housing
✓
Critical Time Intervention
✓
Data and evaluation
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Resource Allocation
Change Strategies
Assessment and Triage: A standardized tool and
process for identifying client/household’s
resources and barriers to housing and for
targeting interventions to meet their needs. Often
used with a coordinated intake model, but can be
used by agencies throughout a community.
Progressive Engagement: A homeless assistance
strategy that provides a small amount of
assistance to everybody who enters the system
and then progressively increasing assistance until
housing crises are resolved.
Diagram of Assessment and Triage Approach
Resource Allocation Checklist
Must haves
Options

Allocation Strategy

Assessment and Triage Strategy
✓
Data on cost effectiveness of programs
✓
Progressive Engagement Strategy
✓
Agreement from providers to only serve people
referred to them
✓
Vulnerability Index
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Mainstream Connections
Change Strategy
Mainstream Employment Connections: Create a
partnership with Workforce Investments Boards
(WIBs), employment programs, and mainstream
income supports to help people who are homeless
to quickly gain employment.
Mainstream Connections Checklist
High Priority
Other Priorities
✓
Employment
✓
Police and Jails
✓
Income and Benefits
✓
Health Care
✓
VA
✓
Mental Health
✓
Schools, Child Care, and Child Development
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