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SNAPS-Shots: Understanding Program Participant Eligibility for ESG Rapid Re-Housing and Homelessness Prevention Components 

April 18, 2013

The Rapid Re-Housing and Homelessness Prevention components of ESG have different eligibility requirements, which are summarized in the following chart. This SNAPS-Shots message does not contain the complete requirements for determining and documenting an individual or family’s eligibility for ESG. 

For complete information on eligibility and documentation requirements, please review the homeless and at risk of homelessness definitions at 24 CFR 576.2, the eligibility criteria at 24 CFR 576.105 and 24 CFR 576.105, and the ESG recordkeeping requirements at 24 CFR 576.500.The Homeless/At Risk Definition guidance may also be helpful.


Initial Evaluation of Eligibility: 

Requirements for Homelessness Prevention – Initial Evaluation 

Individual or family who meets one of the following categories of HUD’s Homeless Definition at §576.2, AND has an annual income below 30% of median family income for the area:

  • Category 2 (Imminent Risk of Homelessness)*
  • Category 3 (Homeless Under Other Federal Statutes)
  • Category 4 (Fleeing/Attempting to Flee Violence, and not living in a place described in Category 1)*

*The definition includes the requirement that individuals and families have no other residence AND lack the resources and support networks to obtain other permanent housing.

OR

Individual or family who meets one of the three categories of HUD’s At Risk of Homelessness Definition at §576.2, AND has an annual income below 30% of median family income for the area:

  • Category 1**
  • Category 2 (Children/youth who do not qualify as homeless under the homeless definition in §576.2 but qualify as homeless under another Federal statute)
  • Category 3 (Children/youth and their families who do not qualify as homeless under the homeless definition in §576.2, but who do qualify as homeless under Section 725(2) of the McKinney-Vento Homeless Assistance Act)

**The definition includes the requirement that individuals and families lack sufficient resources or support networks immediately available to prevent them from moving to an emergency shelter or another place described in Category 1 of the homeless definition.

Note: ESG homelessness prevention assistance is intended to provide rental assistance and housing relocation and stabilization services necessary to prevent an individual or family from moving into an emergency shelter, the streets, or a place not meant for human habitation.

Requirements for Rapid Re-Housing – Initial Evaluation

Individual or family who meets one of the following categories of HUD’s Homeless Definition at §576.2:

  • Category 1 (Literally homeless)
  • Category 4 (Fleeing/Attempting to Flee Violence and living in a place described in Category 1)*

*The definition includes the requirement that individuals and families have no other residence AND lack the resources and support networks to obtain other permanent housing.

As a part of the initial evaluation, recipients/subrecipients are required to determine the amount and type of assistance that the individual or family need to regain stability in permanent housing. They should consider this carefully, and not provide more than the amount needed to help the program participant regain stability in the program participant's current permanent housing or move to permanent housing and achieve stability in that housing.

Remember, too, that recipients must have written standards for evaluating and re-evaluating eligibility for ESG assistance (as well as other written standards, policies and procedures). These standards must be described in the recipient’s Consolidated Plan/Annual Action Plan. Recipients/subrecipients must consistently apply those standards for all program participants. (See the ESG regulation at §576.400(e).)

Re-Evaluations of Eligibility
While program participants receiving Homelessness Prevention assistance must be re-evaluated at least once every three months, program participants receiving Rapid Re-Housing assistance must only be re-evaluated at least once annually, unless the recipient/subrecipient requires more frequent re-evaluations. The chart below summarizes the ESG re-evaluation requirements. (See the ESG regulation at §576.401(a)-(c)).

Re-Evaluations of Eligibility

Component

Frequency

Requirement

Rapid
Re-Housing  

Eligibility and types/amounts of assistance must be re-evaluated not less than once annually.

At a minimum, each re-evaluation must establish and document:

  • The program participant does not have an annual income that exceeds 30% of median family income for the area.
  • The program participant lacks sufficient resources and support networks necessary to retain housing without ESG assistance.

Homelessness Prevention 

Eligibility and types/amounts of assistance must be re-evaluated not less than once every 3 months.


Recipients/subrecipients may require program participants receiving assistance under either component to provide notification regarding changes to household income, household composition, or other circumstances that may impact need for assistance. If such a policy has been established, it must be in the recipient’s written standards, and recipients/subrecipients must re-evaluate participants upon receipt of notification.

If a recipient/subrecipient does not have a policy, the ESG regulation does not require that information about changes in household circumstances received outside of the re-evaluation process trigger a re-evaluation.

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