Determining Homeless Eligibility
Below is standard guidance given to recipients that are dealing with this eligibility issues:
"To be served in HUD's Homeless Assistance Programs, projects funded under the Continuum of Care (CoC) or Emergency Solutions Grants (ESG) Programs, a household must meet the eligibility criteria under the specific program and applicable component type. Staff must document a client's homelessness status at intake into the project, and should follow HUD's stated preferred order for documentation (see section 578.103(a)(3) for more information about recordkeeping requirements for documenting homeless status in the CoC Program interim rule and section 576.500(b) in the ESG Program interim rule).
HUD understands that once a household has been determined eligible and enrolled in a CoC Program-funded permanent housing program, including both rapid re-housing and permanent supportive housing, a unit is not always immediately available—sometimes because the waiting lists are too long or because of the things that must be accomplished to secure a unit (e.g., HQS review or application processing). Communities should be continuously working to improve the system to decrease the amount of time that it takes to secure permanent housing, however, HUD acknowledges that these types of improvements take time.
Therefore, HUD has determined that during this interim period after enrollment but before an appropriate unit has been identified and approved the household will generally continue to reside in an emergency shelter or on the streets, prolonging their period of homelessness. If, during this time, the household is able to spend a few nights with a friend or family or in a hotel or motel, their homeless status (or chronically homeless status, if applicable) and eligibility for the permanent housing program in which they have already been enrolled would not change. If the program participant is not able to wait for the permanent housing placement with a family or friend, and a transitional housing bed (from any funding source) is available, then HUD would allow the program participant to be housed temporarily in that bed while a permanent housing unit is identified. Further, persons that were documented as chronically homeless at the time of intake and enrollment into the permanent housing project can continue to be considered to be chronically homeless status while they wait for their permanent housing unit.
In addition to working to decrease the length of time it takes to locate and house a program participant in a permanent housing unit, HUD expects for CoCs to be routinely reviewing their portfolio of homeless assistance housing options to ensure that the supply reflects the need. This means that if a CoC recognizes that it has many homeless persons that are eligible for permanent supportive housing, for example, but they have more transitional housing available, then they should seriously consider developing a reallocation strategy that would allow them to reduce the number of transitional housing options in favor of creating more permanent supportive housing. HUD recognizes that this takes time and therefore is offering CoCs this flexibility, when the criteria above has been met, so that homeless persons have an alternative to sleeping on the streets when waiting for housing placement that won't jeopardize their eligibility.
HUD encourages CoCs and recipients to follow a Housing First approach and establish policies and procedures that reduce barriers to obtaining a unit and allow recipients to identify and certify units as quickly as possible to reduce the amount of time households wait for units. This could include strategies such as identifying landlords who are willing to work with the recipient, inspecting units for Housing Quality Standards in advance of a household being shown the unit, and identifying landlords who are willing to rent units that are already in compliance with HUD's standards of FMR and rent reasonableness."
Ebony W. Rankin
Special Needs Assistance Specialist
Office of Special Needs Assistance Programs
Community Planning and Development
U.S. Department of Housing and Urban Development
451 7th Street, SW; Room 7256
Washington, DC 20410
phone: (202) 402-2505
