STATE OF ILLINOIS PUBLIC NOTICE
Illinois Department of Human Services
Substantial Amendment to the State of Illinois ESG Program under the Coronavirus Aid, Relief, and Economic Security Act (CARES ACT) for the State of Illinois 2019 Consolidated Plan - Action Plan
Background
After receiving approximately $18.1M in the first round (ESG-CV1), the State of Illinois is receiving approximately $24.7M in the second round (ESG-CV2) of CARES Act funding from the U.S. Department of Housing and Urban Development (HUD) for the Emergency Solutions Grant (ESG) Program. The ESG Program provides funding to:
- Engage homeless individuals and families living on the street;
- Improve the number and quality of emergency shelters for homeless individuals and families;
- Help operate these shelters;
- Provide essential services to shelter residents;
- Rapidly re-house homeless individuals and families; and
- Prevent families and individuals from becoming homeless.
Table 1 - CARES Act ESG Formula Grants in Illinois
| KEY |
STA |
NAME |
ESG-CV1 |
ESG-CV2 |
| 171296 |
IL |
Chicago |
$23,712,993 |
$30,488,553 |
| 179999 |
IL |
Illinois Nonentitlement |
$18,159,983 |
$24,712,992 |
| 179031 |
IL |
Cook County |
$3,049,979 |
$5,812,142 |
| 179043 |
IL |
Du Page County |
$1,031,548 |
$2,483,604 |
| 179097 |
IL |
Lake County |
$777,472 |
$1,520,868 |
| 176000 |
IL |
Rockford |
$636,693 |
$1,157,575 |
| 172238 |
IL |
Evanston |
$546,424 |
$419,890 |
| 175526 |
IL |
Peoria |
$535,321 |
$795,903 |
| 171332 |
IL |
Cicero |
$520,731 |
$784,688 |
| 179197 |
IL |
Will County |
$503,772 |
$973,315 |
|
|
Total |
$49,474,916 |
$69,149,530 |
Nine entitlement communities will receive direct appropriations in addition to the "Nonentitlement" funds appropriated to the State of Illinois (see Table 1, left). These allocations are from the initial funding announcement made by HUD in the amount of $1B out of the total $4B included as provisions under the CARES Act.
The Illinois Department of Human Services (IDHS) administers the ESG Program on behalf of the State of Illinois. ESG Funds are typically allocated though a funding formula to Continuums of Care (CoCs) across the state. A CoC is a regional/local planning body that coordinates housing and services funding for homeless families and individuals across the state.
In Illinois, there are 19 CoCs that cover every geographic area of the state (see Figure 1, right; and Table 2, Page 2). CoC Geographic Coverage Areas do not perfectly align with the entitlement communities that directly receive ESG appropriations (other than Chicago). For example, the Peoria allocation is for only Peoria whereas the CoC covers Peoria, Tazewell, and Woodford Counties. IDHS therefore generally funds every CoC for the ESG Program except for Chicago through the formula allocation.
CoCs also have generally been allowed the flexibility to determine how their funding allocation gets distributed within their geographic coverage area among eligible providers as well as determining the funding levels for each of the eligible activities (within some predetermined limitations) after the individual CoC allocation amounts have been provided to them. IDHS's vetted formula that utilizes local population and other poverty statistics has proven to be a fair and equitable way to distribute funds statewide, but the funding levels needed for each eligible activity varies greatly among the CoCs and the communities they serve based on the availability of other local resources and the local human services infrastructure.
Table 2 - Illinois Continuums of Care (CoCs) and Geographic Coverage Area
| COC # |
COC NAME |
COUNTIES/CITY SERVED |
| IL-500 |
McHenry County Continuum of Care |
McHenry |
| IL-501 |
Rockford/Winnebago/Boone Continuum of Care |
Winnebago, Boone, DeKalb |
| IL-502 |
Lake County Continuum of Care |
Lake |
| IL-503 |
Champaign County Continuum of Care |
Champaign |
| IL-504 |
Madison County Continuum of Care |
Madison |
| IL-506 |
Will County Continuum of Care |
Will, Kendall, Grundy |
| IL-507 |
Heart of Illinois Continuum of Care |
Peoria, Fulton, Tazewell, Woodford |
| IL-508 |
St. Clair County Continuum of Care |
St. Clair |
| IL-510 |
City of Chicago Continuum of Care |
City of Chicago |
| IL-511 |
Cook County Continuum of Care |
Cook |
| IL-512 |
Central Illinois Continuum of Care |
DeWitt, Ford, Iroquois, Kankakee, Livingston, Logan, Mason, Menard, McLean, Piatt, Vermilion |
| IL-513 |
Heartland Continuum of Care |
Sangamon |
| IL-514 |
DuPage County Continuum of Care |
DuPage |
| IL-515 |
South-Central Illinois Continuum of Care |
Calhoun, Christian, Clark, Clay, Coles, Crawford, Cumberland, Douglas, Edgar, Effingham, Fayette, Greene, Jasper, Jersey, Macoupin, Montgomery, Moultrie, Shelby |
| IL-516 |
Decatur/Macon Co. Continuum of Care |
Macon |
| IL-517 |
Continuum of Care for Kane County |
Kane |
| IL-518 |
Northwestern Continuum of Care |
Bureau, Carroll, Jo Daviess, Henry, Knox, LaSalle, Lee, Marshall, Mercer, Ogle, Putnam, Rock Island, Stark, Stephenson, Whiteside |
| IL-519 |
West Central Illinois Continuum of Care |
Adams, Brown, Cass, Hancock, Henderson, McDonough, Morgan, Pike, Schuyler, Scott, Warren |
| IL-520 |
Southern Illinois Continuum of Care |
Alexander, Bond, Clinton, Edwards, Franklin, Gallatin, Hamilton, Hardin, Jackson, Jefferson, Johnson, Lawrence, Marion, Massac, Monroe, Perry, Pope, Pulaski, Randolph, Richland, Saline, Union, Wabash, Washington, Wayne, White, Williamson |
Additional basic information about the ESG program and eligible activities can be reviewed in HUD's ESG Basics for State Recipients resource. Many services funded through ESG are exempt from immigration restrictions, and anyone, regardless of immigration status, can receive services through street outreach, emergency shelter, and rapid re-housing activities. Financial assistance that provides rental assistance payments on behalf of individuals and families is restricted to eligible immigrants.
To formulate a proposal for the second round of the CARES Act ESG Funding, IDHS leadership and staff:
- Engaged in ongoing communication with CoCs, providers, and advocacy groups about their increased local community needs for assistance during the COVID-19 pandemic, including organizational needs at the provider level to sustain services and respond to the increased demand. Additionally, a CoC questionnaire was developed, distributed, and returned for CoCs to systematically report ongoing needs and challenges.
- Reviewed the existing programs/funding sources administered within the state that also provide support to the homeless and at-risk populations. This analysis included a review of Emergency Shelter, Homeless Prevention, Rapid Rehousing, Eviction Mitigation, Legal Services, and other programming such as Administration, Data Collection and Street Outreach. Analysis also took into consideration prospective funding opportunities available through Federal Emergency Rental Assistance funds that were a part of the 2020 Omnibus COVID Relief Bill as well as the American Rescue Plan Act of 2021. There was a particular focus on programs/resources that have been implemented during the ongoing COVID-19 pandemic and the need to ensure deduplication of services among all the various programs funding these activities.
- Analyzed the program expenditure rates for ESG-CV1 (first round) to identify any potential need to adjust funding distribution methodologies both between and within CoCs in Illinois.
Analysis
Leadership first considered systematically gathered feedback from our CoCs and their provider organizations about the ongoing and increased needs they are seeing in their communities as the pandemic has progressed. Their feedback is summarized below:
18 CoCs (100%) reported increased need for Emergency Shelter activities
- 12 CoCs reported a need to add additional facilities with 7 CoCs reporting a need for temporary shelter facilities.
- 10 CoCs reported a range of increased need from 15-40%.
- 8 CoCs reported significant increased needs - from 60% up to double what was funded through the previous round.
- Specific communicated needs included: continuing utilization of hotel/motel vouchers; need for new, fixed site shelter development to replace rotating site models, and sustaining seasonal shelters throughout the year during the pandemic.
16 CoCs (89%) reported increased need for Rapid Rehousing activities
- 8 CoCs reported increased need in unknown amounts - they are unsure of how significantly needs will increase once eviction moratoriums are lifted.
- 4 CoCs reported increased need at or near 50%.
- 3 CoCs reported a range of increased need from 25-35%.
- 1 CoC reported they will continue to focus most of their ESG funds on Rapid Rehousing.
- Many CoCs are concerned about the unknown demand that may arise after eviction moratoriums are lifted; some CoCs are concerned about how consumers will afford rent after the assistance limits are reached as they reported significant challenges in their consumer finding and competing for employment opportunities.
15 CoCs (83%) reported increased need for Administrative funding
- 5 CoCs reported increased need of 15% or less.
- 5 CoCs reported increased need of 20-50%.
- 5 CoCs reported that increases were needed in undefined amounts.
14 CoCs (78%) reported increased need for Homeless Prevention funding
- 9 CoCs reported a wide range of increased need from 4-50%.
- The remaining CoCs reported difficulty in estimating the % of increased need because of the eviction moratoriums and other rental assistance/eviction prevention resources.
- Several CoCs responded with their ongoing concerns that the eviction moratoriums and documentation requirements for eligibility are inhibiting their use of homeless prevention funds.
- Concerns were expressed about potentially very high demands once the eviction moratoriums are lifted and whether other eviction mitigation resources will be sufficient in responding to those demands.
12 CoCs (67%) reported increased need for HMIS funding
- 5 CoCs reported
- 4 CoCs reported a range of increased need from 25-50%
- 3 CoCs reported a small increased need of 10% or less
8 CoCs (44%) reported increased need for Street Outreach funding
- 4 CoCs reported a 10% increase in need
- 1 CoC reported a 7% increase
- 2 CoCs reported significant increases needed - up to double the previous round
- 1 CoC reported a need not funded through ESG previously
CoCs also reported that:
- One of the primary and most reported concerns has been the use of Homeless Prevention funds during the eviction moratoriums. The eligibility and documentation standards are too narrow to permit the most frequently requested financial assistance. Their concern is that the months of unpaid back rent will be beyond the scope of program limitations and also that the corresponding delays in rent payment will create a bottleneck of applicants that they will not be able to address in a manner timely enough to prevent eviction for all of the households.
- About one quarter of the CoCs are considering adding additional/new providers to those implementing ESG services in their communities. About half do not anticipate adding providers and the remaining quarter are unsure or are considering adding providers.
- Most CoCs have solid plans and services in place to move individuals from congregate shelters and hotels/motels to more independent and permanent settings, but there are some concerns about whether homeless persons who have been rapidly rehoused will be able to sustain the housing costs once program limitations for assistance have been reached. They are seeing a decrease in household income and increase in the levels of services needed. Some report an increased need of permanent supportive housing to support some consumers - though not an eligible ESG activity. Others have reported their consumers have increased "lengths of stay" in their programs because of limited income and employment opportunities.
- Providers have communicated their ongoing challenges with budgeting for staff and administrative costs which have only increased during the pandemic. This is exacerbated by the fact that most non-profit organizations have experienced dramatic decreases in their ability to fundraise and meet the increased costs with flexible funding sources.
Leadership then reviewed the other new and existing programs/funding sources administered within the state and found:
Emergency Shelter - ESG is one of the only federal or state sources that funds the ongoing operational expenses for homeless shelters and hotel/motel costs. While the state's Emergency and Transitional Housing Program (ETH) also funds these activities, funding levels are not sufficient for significant expansion.
CDBG and a few other resources are being also being utilized at local levels to help with the acquisition/rehabilitation of additional facilities, but ESG funds are critical to the ongoing operational expenses. FEMA funds were also critical during the pandemic in assisting shelters with placing populations in hotels/motels when quarantine periods were necessary, but it is not a viable source for the ongoing need to decrease the numbers of individuals reliant on congregate shelter settings with a lower capacity than during pre-pandemic conditions.
Rapid Rehousing - Many of the programs currently being implemented for rental assistance are focused on preventing evictions, paying back rent, and keeping people in their existing homes. ESG remains the primary and often exclusive source for moving people who have become homeless back into permanent settings.
Homeless Prevention - This activity has been the most complex and difficult set of services to coordinate with the other available resources. Various rental assistance and eviction mitigation program have been and are continuing to be implemented to reduce the number of people that will lose their homes because of the economic conditions caused by the pandemic once moratoriums have been lifted.
Many of these programs do not have the same restrictions on eligibility that prevent our ESG providers from expending funds for rental assistance while the eviction moratoriums are in place and it is unknown how many will remain unserved once those programs have obligated all of their resources. For these reasons, CoCs have been encouraged and instructed to prioritize other eligible ESG activities to the maximum extent appropriate until such time as the moratoriums have been lifted.
The State of Illinois, under the management of the Illinois Housing Development Authority (IHDA), has database in place for providers of the various federally-funded programs to record financial assistance provided to their consumers as a way to ensure services are not duplicated. Moving forward, providers of Homeless Prevention services funded through the ESG program will be required to utilize this database.
Street Outreach - ESG remains the primary source of funding for ongoing Street Outreach activities since few other resources have been made available for this activity in limited amounts.
HMIS - ESG, HUD Homeless Assistance grants, and local resources remain the only sources of funding that support this activity.
Administrative - Most of the assistance programs that have been implemented in response to COVID-19 are very limited in the amount or percentage of funds that can be used for administrative purposes. However, these added programs and funding streams have only increased the need for administrative activities to coordinate and implement the services funded by the programs. Programs that use state-negotiated administrative rates tend to have much higher limits in this category than when programs limit administrative expenses to a specific percentage or amount - making it challenging for organizations to manage the increase administrative burden.
Finally, leadership decided to analyze current program expenditure rates through the end of February 2021 for ESG-CV1 (first round) funding to identify any potential need to adjust funding distribution methodologies both between and within CoCs in Illinois. Table 3 (below) shows the expenditures for each CoC and Figure 2 (next page) shows how many providers statewide fall into which expenditure rate categories.
Table 3 - ESG-CV1 Expenditures by Continuum of Care (CoC) through February 2021
| CoC # |
Continuum of Care Name |
Total Allocation |
Total Expenditures |
Percent Expended |
| IL-500 |
McHenry County Continuum of Care |
$469,152 |
$149,387 |
32% |
| IL-501 |
Rockford/Winnebago/Boone Continuum of Care |
$1,060,759 |
$259,995 |
25% |
| IL-502 |
Lake County Continuum of Care |
$1,153,509 |
$387,011 |
34% |
| IL-503 |
Champaign County Continuum of Care |
$559,740 |
$39,687 |
7% |
| IL-504 |
Madison County Continuum of Care |
$584,428 |
$10,001 |
2% |
| IL-506 |
Will County Continuum of Care |
$1,257,948 |
$525,647 |
42% |
| IL-507 |
Heart of Illinois Continuum of Care |
$846,351 |
$89,698 |
11% |
| IL-508 |
St. Clair County Continuum of Care |
$709,321 |
$127,507 |
18% |
| IL-511 |
Cook County Continuum of Care |
$2,083,641 |
$604,984 |
29% |
| IL-512 |
Central Illinois Continuum of Care |
$1,249,916 |
$126,875 |
10% |
| IL-513 |
Heartland Continuum of Care |
$473,912 |
$118,431 |
25% |
| IL-514 |
DuPage County Continuum of Care |
$1,379,759 |
$374,915 |
27% |
| IL-515 |
South-Central Illinois Continuum of Care |
$961,839 |
$191,981 |
20% |
| IL-516 |
Decatur/Macon Co. Continuum of Care |
$302,742 |
$144,918 |
48% |
| IL-517 |
Continuum of Care for Kane County |
$970,602 |
$87,318 |
9% |
| IL-518 |
Northwestern Continuum of Care |
$1,972,674 |
$303,032 |
15% |
| IL-519 |
West Central Illinois Continuum of Care |
$550,857 |
$134,001 |
24% |
| IL-520 |
Southern Illinois CoC |
$1,572,833 |
$164,201 |
10% |
|
Total |
$18,159,983 |
$3,839,589 |
21% |
Figure 2 - Number of Providers by Expenditure ESG-CV1 Rate through February 2021
| Expenditure Rate |
Number of Providers |
| 0% |
11 |
| 1-10% |
17 |
| 11-20% |
23 |
| 21-30% |
10 |
| 31-50% |
13 |
| 51-99% |
13 |
| 100% |
1 |
The notable findings on the review expenditures include:
- Only 21% of ESG-CV1 had been expended through the reporting periods thus far
- Half of CoCs have expended less than 25% of their allocations
- 2 CoCs have expended more than 40% of their allocations
- 7 CoCs have providers who have not yet reported any expenditures
- 11 providers have not yet reported any expenditures
- 1 provider has expended all its funding
- Expenditure rates vary greatly by CoC and by Provider
Funding Distribution & Allocations
CoCs remain the experts in planning their local homeless response systems of care, identifying eligible providers as funding recipients, and determining the appropriate balance of funding among the eligible cost activities for their respective geographic areas. While CoCs will not be limited within the eligible cost categories beyond what is required by statutes and/or regulation, we strongly encouraged CoCs to prioritize ESG-CV2 funds for Emergency Shelter and Rapid Rehousing activities aside from clear needs among the other categories. This is based on available resources and what was reported by CoCs. Their requests, when consolidated, have informed the final funding allocations being included in the substantial amendment to the state's consolidated plan - administered by the Illinois Housing Development Authority (IHDA).
While there are concerns regarding capacity and expenditure rates for ESG-CV1, IDHS has elected not to amend its geographic distribution formula for the second round ESG funding made available through the Cares Act. However, IDHS will monitor ongoing expenditures, provide support in assisting providers and CoCs in the timely expenditure of contracted funds, connect providers with any technical assistance resources they may need, and the following conditions will apply:
- Provider performance and expenditure rates will be monitored closely and communicated to CoCs
- CoCs may be required to reallocate ESG funding between their providers based on performance/expenditures
- IDHS reserves the right to redistribute funds between CoCs based on performance/expenditure rates or a CoC may elect to voluntarily relinquish funds, under the following conditions:
- A CoC has been notified of its underperformance;
- The CoC has had an opportunity to submit a plan for correcting its performance that includes any plans to reallocate funds among its providers, reallocate funds among the eligible activities, and/or any technical assistance needs that the CoC or its providers may need in order to correct its performance;
- The CoC does not correct its performance or has not viable plan for doing so; and
- Funds will be redistributed according to the existing distribution formula among CoCs requesting and/or willing to accept additional funds.
IDHS has recently initiated a technical assistance (TA) engagement with HUD and asked them and their technical assistance providers to help us focus on how we can enhance administrative and service capacity in our provider network. We hope to work with them to identify ways we can utilize different funding streams across the state, including new American Rescue Plan Act (ARPA) dollars, to allow providers to increase capacity to hire permanent staff and sustainably increase their reach in the community. We hope to then work with CoCs and their providers to help them better understand how to leverage funds for these purposes and how to navigate challenges, like hiring, that can inhibit their ability to grow to meet the community needs.
IDHS will remain flexible in the funding allocations among eligible activities as our CoCs and providers continue to provide services, access technical assistance resources, and adjust to the ever-changing landscape during the ongoing conditions of the pandemic. Subsequent substantial amendments to the state's consolidated plan may be required should any significant changes to the distribution be necessary.
IDHS will notify each Continuum of Care (CoC) Representative of the award amount for their region based on IDHS's vetted formula that utilizes local population and other poverty statistics. Tables 4 and 5 (below) show the distribution of funds geographically and the total amounts that will be allocated under each eligible activity to the CoCs across the State of Illinois.
Table 4 - Geographic Distribution for ESG-CV2 Funding
| CoC # |
Continuum of Care Name |
Program Allocation |
Admin Allocation |
Total Allocation |
| IL-500 |
McHenry County Continuum of Care |
$574,601 |
$63,845 |
$638,446 |
| IL-501 |
Rockford/Winnebago/Boone/DeKalb Continuum of Care |
$1,299,179 |
$144,353 |
$1,443,532 |
| IL-502 |
Lake County Continuum of Care |
$1,412,776 |
$156,975 |
$1,569,751 |
| IL-503 |
Champaign County Continuum of Care |
$685,549 |
$76,172 |
$761,721 |
| IL-504 |
Madison County Continuum of Care |
$715,786 |
$79,532 |
$795,318 |
| IL-506 |
Will County Continuum of Care |
$1,540,688 |
$171,188 |
$1,711,876 |
| IL-507 |
Heart of Illinois Continuum of Care |
$1,036,580 |
$115,176 |
$1,151,756 |
| IL-508 |
St. Clair County Continuum of Care |
$868,751 |
$96,528 |
$965,279 |
| IL-511 |
Cook County Continuum of Care |
$2,551,969 |
$283,552 |
$2,835,521 |
| IL-512 |
Central Illinois Continuum of Care |
$1,530,852 |
$170,095 |
$1,700,947 |
| IL-513 |
Heartland Continuum of Care |
$580,431 |
$64,492 |
$644,923 |
| IL-514 |
DuPage County Continuum of Care |
$1,689,879 |
$187,764 |
$1,877,643 |
| IL-515 |
South-Central Illinois Continuum of Care |
$1,178,026 |
$130,892 |
$1,308,918 |
| IL-516 |
Decatur/Macon Co. Continuum of Care |
$370,788 |
$41,199 |
$411,987 |
| IL-517 |
Continuum of Care for Kane County |
$1,188,758 |
$132,084 |
$1,320,842 |
| IL-518 |
Northwestern Continuum of Care |
$2,416,060 |
$268,451 |
$2,684,511 |
| IL-519 |
West Central Illinois Continuum of Care |
$674,670 |
$74,963 |
$749,633 |
| IL-520 |
Southern Illinois CoC |
$1,926,349 |
$214,039 |
$2,140,388 |
|
Totals |
$22,241,692 |
$2,471,300 |
$24,712,992 |
Table 5 -ESG-CV2 Funding Allocations Among Eligible Activities
| Amount |
Funding Source |
Eligible Activity |
| $8,613,694 |
ESG-CV2 |
Emergency Shelter |
| $6,358,395 |
ESG-CV2 |
Homeless Prevention |
| $5,560,857 |
ESG-CV2 |
Rapid Re-housing |
| $1,033,406 |
ESG-CV2 |
Street Outreach |
| $687,026 |
ESG-CV2 |
HMIS/Data Collection |
| $2,459,614 |
ESG-CV2 |
Administrative Activities |
