SECTION 5: Eligible Activities

The following pages detail information regarding the types of activities that may be provided using ESG funds.

There are six major eligible activities under ESG:

1. Street Outreach
2. Emergency Shelter (includes supportive services)
3. Rapid Rehousing
4. Homelessness Prevention
5. HMIS
6. Administration

The following sections provide detailed information regarding the types of ESG funded eligible activities:

A. Street Outreach (24 CFR §576.101)

Eligible Program Participants:

* Unsheltered individuals and families, meaning those who qualify under paragraph (1)(i) of the definition of "homelessness".

Overview of Eligible Activities:

• The eligible costs for street outreach activities differ from the eligible costs for essential services related to emergency shelter, as they are limited to those necessary to provide emergency care on the street.
• Services charged to this activity must only include costs of helping eligible participants residing on the street or in parks, abandoned buildings, bus stations, campgrounds, and other such settings where unsheltered persons are staying.
• Staff salaries related to carrying out street outreach activities is also available.

Eligible Costs:

• ESG funds may be used for costs of providing essential services necessary "ON THE STREET" to:
  • Reach out to unsheltered homeless people;
  • Connect them with emergency shelter, housing or critical services; and
  • Provide urgent non-facility-based care to unsheltered homeless participants who are unwilling or unable to access emergency shelter, housing or an appropriate health facility.
• For this section, "unsheltered homeless" means individuals and families who qualify as homeless under the new definitions.

1. Specific eligible costs consist of the following:
   1. Engagement - The costs to locate, identify, and build relationships with unsheltered homeless people and engage them for the purposes of providing immediate support, intervention, and connections with homeless assistance programs and/or mainstream social services and housing programs.
   2. Case Management - Includes the cost of assessing housing and service needs; arranging, coordinating, and monitoring the delivery of individualized services to meet the needs of the program participants. Includes using the centralized or coordinated assessment system developed by the local Continuum of Care as mandated by HUD; conducting initial evaluation including verifying and documenting eligibility, counseling, developing; securing and coordinating services, etc.
   3. Emergency Health Services - Includes costs for direct outpatient treatment of medical conditions provided by licensed medical professionals operating in community-based settings, including streets, parks, and other places where unsheltered homeless people are living. Funds may be used only for these services to the extent that other appropriate health services are inaccessible or unavailable within the area. Eligible treatment consists of accessing a program participant's health problems and developing a treatment plan; assisting participants to understand their health needs; providing directly or assisting program participants to obtain appropriate emergency medical treatment; and providing medication and follow-up services.
   4. Emergency Mental Health Services - Includes costs for direct outpatient treatment by licensed professionals of mental health conditions operating in community-based settings, including streets, parks, and other places where unsheltered people are living. Funds may be used only for these services to the extent that other appropriate mental health services are inaccessible or unavailable within the community. Mental health services are the application of therapeutic processes to personal, family, situational, or occupational problems to bring out positive resolution of the problem or improved individual or family functioning or circumstances. Eligible treatment consists of crisis intervention, the prescription of psychotropic medications, explanation about the use and management of medications, and combinations of therapeutic approaches to address multiple problems.
   5. Transportation - Includes transportation costs by outreach workers, social workers, medical professionals, or other service subrecipients, provided that this travel takes place during the provisions of services eligible under this section. The costs of transporting unsheltered people to emergency shelters or other service facilities are also eligible. These costs include:
      1. The cost of a program participant's travel on public transportation;
      2. If service workers use their own vehicles, mileage allowance for service workers to visit program participants;
      3. The cost of purchasing or leasing a vehicle for the subrecipient in which staff transports program participants and/or staff serving program participants, and the cost of gas, insurance, taxes and maintenance for the vehicle; and
      4. Travel costs of agency staff to accompany or assist the program participants to use public transportation.
   6. Services for Special Population - Funds may be used to provide services for homeless youth, victim services, and services for people living with HIV/AIDs, so long as the costs of providing these services are eligible under program regulations. The term "victim services" means services that assist program participants who are victims of domestic violence, dating violence, sexual assault, or stalking, including services offered by rape crisis centers, DV shelters, and other organizations with a documented history of effective work concerning domestic violence, dating violence, sexual assault or stalking.

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B. Emergency Shelter Essential Services (24 CFR §576.102)

Eligible Program Participants:

* Individuals and families who are in an emergency shelter.

Eligible Costs:

Case Management - The cost of assessing, arranging, coordinating and monitoring the delivery of individualized services to meet the needs of the program participant. Component services and activities consist of:

1. Case Management - The cost of assessing, arranging, coordinating and monitoring the delivery of individualized services to meet the needs of the program participant. Component services and activities consist of:
   1. Using the centralized or coordinated assessment system developed by the local Continuum of Care as mandated by program regulations
   2. Conducting the initial evaluation
   3. Counseling
   4. Developing, securing, and coordinating services and obtaining Federal, state and local benefits
   5. Monitoring and evaluating program participant progress
   6. Providing information and referrals to other programs
   7. Providing ongoing risk assessment and safety planning with domestic violence, dating violence, sexual assault and stalking victims
   8. Developing an individualized housing and service plan, including planning a path to permanent housing stability.
2. Child Care - The cost of child care for program participants, including providing meals and snacks, and comprehensive and coordinated sets of appropriate developmental activities are eligible. Children must be under the age of 13 unless they are disabled. Disabled children must be under the age of 18. The child-care center must be licensed by the jurisdiction in which it operates.
3. Education Services - When necessary for program participants to obtain and maintain housing, the costs of improving knowledge and basic educational skills are eligible. Services include instruction or training in consumer education, health education, substance abuse prevention, literacy, English as a Second Language (ESL) and GED. Component services of activities are screening, assessment and testing, individual or group instruction, tutoring, provision of books, supplies, and instructional material, counseling and referral to community resources.
4. Employment Assistance and Job Training - The costs of employment assistance and job training programs are eligible. Services will assist the individuals in securing employment, acquiring learning skills, and/or increasing earning potential. Cost of providing reasonable stipends to program participants in employment assistance and job training programs. Learning skills including those skills that that can be used to secure and retain a job, including the acquisition of vocational licenses and/or certificates.
   1. Eligible types include:
      1. Classroom instruction
      2. Online instruction
      3. Computer instruction
      4. On the job instruction
   2. Specific services that assist individuals in securing employment including:
      1. Employment screening, assessment or testing
      2. Structured job skills and job-seeking skills
      3. Special training and tutoring, including literacy training and prevocational training
      4. Books and instructional material
      5. Counseling or job coaching
      6. Referral to community resources
5. Outpatient Health Service - Costs for direct outpatient treatment of medical conditions provided by licensed medical professionals. Funds may be used only for these services to the extent that other appropriate health services are unavailable within a community.
   • Eligible treatment consists of:
     1. Assessing a program participant's health problems
     2. Developing a treatment plan
     3. Assisting participants to understand health needs
     4. Providing directly or assisting participants to obtain appropriate medical treatment
     5. Preventive medical care
     6. Health maintenance service, including emergency medical services
     7. Providing medications and follow-up services, and
     8. Providing preventive and non-cosmetic dental care
6. Legal Services - Legal services MUST be necessary to resolve a legal problem that prevents a participant from obtaining or maintaining permanent housing.
   • Eligible subject matters include:
     1. Child support, guardianship, paternity, emancipation, and legal separation
     2. Orders of protection and
     3. Other civil remedies for victims of domestic violence, dating violence, sexual assault, d stalking
     4. Appeal of veterans and public benefit claim denials, and
     5. Resolution of outstanding criminal warrants
   • Eligible costs include hourly fees for legal advice and representation by attorneys. Fees based on the actual service performed (i.e. fee for service) can only be supported with ESG funds if the cost is less than the hourly fee. Other eligible costs may include participant intake, preparation of cases for trial, provisions of legal advice, representation at hearings, counseling, filing fees, and other necessary court costs. Subrecipient's employees' salaries and other costs necessary to perform the services are eligible, if the subrecipient is a legal services Subrecipient and performs the services itself.
7. Life Skills Training - Costs of teaching critical life management skills that may never have been learned or have been lost during the course of physical or mental illness, DV, substance abuse, and homelessness are eligible costs. These services must be necessary to assist the program participant to function independently. Component life skills training are budgeting resources, managing money, managing a household, resolving conflict, shopping for food and needed items, improving nutrition, using public transportation and parenting.
8. Mental Health Services - Costs include direct outpatient treatment by licensed professionals of mental health conditions. Funds may only be used for these services to the extent that other appropriate mental health services are unavailable or inaccessible within the community. Mental health services are the application of therapeutic process to personal, family, situational or occupational problems to bring about positive resolution of the problem or improved functioning or circumstances.
   • Problem areas may include:
     • Family and martial relationships
     • Parent-child problems
     • Symptom management
   • Eligible treatment consists of crisis intervention, therapy sessions, prescription of psychotropic medications, or explanations about the use and management of medications, and combinations of therapeutic approaches to address multiple problems.
9. Substance Abuse Treatment Service - Eligible substance abuse treatment services are designed to prevent, reduce, eliminate, or deter relapse of substance abuse or addictive behaviors and are provided by licensed or certified professionals. Funds may only be used for these services to the extent that other appropriate substance abuse treatments services are unavailable or inaccessible within a community. Eligible treatment consists of:
   • • Participant intake and assessment
     • Outpatient treatment for up to 30 days
     • Group and individual counseling and drug testing
   • Note: Impatient detoxification and other inpatient drug or alcohol treatments are INELIGIBLE.
10. Transportation - Costs consist of the transportation costs of a program participant's travel to and from medical care, employment, childcare, or other eligible essential services facilities. These costs include the following:
    • 1. The cost of a program participant's travel on public transportation,
      2. If service workers use their own vehicles, mileage allowance for service workers to visit program participants,
      3. The cost of purchasing or leasing a vehicle for the subrecipient in which staff transports program participants and/or staff serving program participants, and the cost of gas, insurance, taxes and maintenance of the vehicle, and
      4. The travel costs of subrecipient staff to accompany or assist program participants to use public transportation.
    • NOTE: Funds may no longer be used to provide fuel vouchers, bus tickets, or other transportation activities unless it directly involves participation in other ESG-funded activities.
11. Services for Special Populations - Funds may be used to provide services for homeless youth, victim services, and services for people living with HIV/AIDs, so long as the cost of providing these services are eligible. The term "victim services" means services that assist program participants who are victims of domestic violence, dating violence, sexual assault, or stalking, including services offered by rape crisis centers and domestic violence shelters, and other organizations with a documented history of effective work concerning these issues.

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C. Emergency Shelter Operations

Eligible Program Participants:

• Individuals and families who reside in emergency shelter (as defined by HUD).

Definition of an Emergency Shelter:

• Emergency shelter means any facility, the primary purpose of which is to provide a temporary shelter for the homeless in general or for specific populations of the homeless and which does not require occupants to sign leases or occupancy agreements.
• Where no appropriate emergency shelter is available for a homeless individual or family, eligible costs may also include a hotel or motel voucher.
• Any project funded as an emergency shelter under a Fiscal Year 2010 Emergency Solutions grant may continue to be funded under ESG.
• Day shelters may be considered Emergency Shelters, if:
  • Participants are homeless (with documentation of their status maintained),
  • Participants and activities are entered into a HMIS/Comparable database, and
  • Program follows the written standards related to emergency shelters and essential services under 24 CFR § 576.400(e).
• If a shelter serves both eligible and ineligible participants under ESG, then the shelter's eligible costs must be allocated in proportion to "the relative benefits received."
• The following DO NOT qualify as eligible emergency shelters for ESG:
  • Group home or other institutional setting;
  • A doctor's office or other facility where a person can only stay for the time of his/her appointment;
  • Multi-purpose service centers serving all people in need; or
  • Stand-alone food pantries/soup kitchens/cafeterias.
• Communities should fund activities in day shelters that are targeted to people who are sleeping on the streets or in emergency shelter.

Eligible Costs:

Operation of a Homeless Shelter - Costs of maintenance including:

1. Minor or routine repairs
2. Rent
3. Food
4. Security
5. Fuel
6. Equipment
7. Telephone/cell phone service
8. Internet expense
9. Furnishings
10. Office supplies
11. Insurance- Utilities, and
12. Other supplies necessary for the operation of the shelter(s).

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D. Homelessness Prevention (24 CFR §576.103)

Eligible Program Participants:

Individuals and families who are at IMMINENT RISK or at RISK OF HOMELESSNESS, meaning they qualify under paragraph (2) and (3) of the homeless definition OR qualify as at risk of homelessness.

You can refer to the flowchart ESG Homelessness Prevention and Rapid Rehousing Eligibility Determination Flow Chart (pdf) to determine whether a participant is eligible for Rapid Rehousing or Homelessness Prevention assistance.

Overview of Eligible Activities:

Generally, the intent of Homelessness Prevention assistance is to quickly transition program participants to stability, either through their own means or through public benefits, as appropriate.

Participants may maintain their current housing or move into new housing.

Assistance should be focused on housing stabilization, linking program participants to community resources and mainstream benefits, and helping them develop a plan for preventing future housing instability.

Financial Assistance:

• Short-term rental assistance (3 months)
• Medium-term rental assistance (4 to 24 months)
• Rent arrearages (up to 6 months)
• Security deposits and Utility deposits (but only in a new apartment)
• Utility payments (up to 18 months including up to 6 months' arrearages)
• Moving cost assistance
• Staffing and operating costs associated with implementing eligible financial assistance activities

Housing Relocation and Stabilization Services:

• Case management
• Outreach and engagement
• Landlord/Tenant Education
• Housing search and placement (includes inspections)
• Legal services
• Credit repair/Financial Counseling

NOTE: Motel/hotel vouchers are not an eligible expense under Rapid Rehousing or Homelessness Prevention assistance.

1. Specific eligible costs consist of the following:
   • Housing Relocation and Stabilization Services
     1. Financial Assistance Costs - ESG funds may ONLY be used to pay housing owners, utility companies, and other third parties for the following costs (cannot pay funds directly to participant):
     2. Rental application fees - ESG can support Fee, only if Fee is charged by the owner to ALL applicants, not just participant(s) receiving assistance.
     3. Security deposits - Equal to no more than 2 months' rent.
     4. Last month's rent - If necessary to obtain housing, the last month's rent may be paid from ESG funds to the owner of that housing at the time the owner is paid the security deposit and the first month's rent. This assistance must not exceed one month's rent and MUST be included in calculating the program participant's total rental assistance, which cannot exceed 24 months during any 3-year period.
     5. Utility deposits - Only can support a utility deposit that is required by the utility company for all customers (only for gas, electric, water, and sewage).
     6. Utility payments - ESG funds may pay for up to 24 months of utility payments per program participant, per service, including up to 6 months of utility payments in arrears, per service.
        1. A partial payment of a utility bill counts as one month.
        2. This assistance may only be provided if the program participant or a member of the same household has an account in their name with a utility company or proof of responsibility to make utility payments.
        3. Eligible utility services are gas, electric, water, and sewage.
        4. No program participant shall receive more than 24 months of utility assistance within any 3-year period.
     7. Moving costs - ESG funds may pay for moving costs, such as truck rental or hiring a moving company.
        1. This assistance may include payment of temporary storage fees for up to 3 months, provided that the fees are accrued after the date the program participant begins receiving assistance and before the program participant moves into permanent housing.
        2. Payment of temporary storage fees in arrears is not eligible.
     8. Services Costs. ESG funds may be used to pay the costs of providing the following services:
     9. Housing search and placement - Services or activities necessary to assist program participants in locating, obtaining, and retaining suitable permanent housing, include the following:
        1. Assessment of housing barriers, needs, and preferences;
        2. Development of an action plan for locating housing;
        3. Housing search;
        4. Outreach to and negotiation with owners;
        5. Assistance with submitting rental applications and understanding leases;
        6. Assessment of housing for compliance with Emergency Solutions Grant (ESG) requirements for habitability, lead-based paint, and rent reasonableness;
        7. Assistance with obtaining utilities and making moving arrangements; and
        8. Tenant counseling.
     10. Housing stability case management - ESG funds may be used to pay cost of assessing, arranging, coordinating, and monitoring the delivery of individualized services to facilitate housing stability for a program participant who resides in permanent housing or to assist a program participant in overcoming immediate barriers to obtaining housing. This assistance cannot exceed 30 days during the period the program participant is seeking permanent housing and cannot exceed 24 months during the period the program participant is living in permanent housing. Component services and activities consist of:
         1. Using the Coordinated Entry system to evaluate participants applying for or receiving assistance;
         2. Conducting the initial evaluation, including verifying and documenting eligibility;
         3. Counseling;
         4. Developing, securing, & coordinating services/benefits;
         5. Monitoring and evaluating program participant progress;
         6. Providing information and referrals to other Subrecipients;
         7. Developing an individualized housing and service plan, including a path to permanent housing stability; and
         8. Conducting re-evaluations required under §576.401(b).
     11. Mediation - ESG funds may pay for mediation between the program participant and the owner or person(s) with whom the program participant is living, provided that the mediation is necessary to prevent the program participant from losing permanent housing in which the program participant currently resides.
     12. Legal services - Legal services MUST be necessary to resolve a legal problem that prevents a participant from obtaining or maintaining permanent housing.
         • Eligible subject matters include:
           • 1. Landlord/tenant matters
             2. Child support, guardianship, paternity, emancipation, and legal separation,
             3. Orders of protection and
             4. Other civil remedies for victims of domestic violence, dating violence, sexual assault, and stalking,
             5. Appeal of veterans and public benefit claim denials, and
             6. Resolution of outstanding criminal warrants.
           • Eligible costs include hourly fees for legal advice and representation by attorneys.
           • Fees based on the actual service performed (i.e. fee for service) can only be supported with ESG funds if the cost is less than the hourly fee.
           • Other eligible costs may include participant intake, preparation of cases for trial, provisions of legal advice, representation at hearings, counseling, filing fees, and other necessary court costs. Subrecipient's employees' salaries and other costs necessary to perform the services are eligible if the subrecipient is a legal services Subrecipient and performs the services itself.
           • Note: Legal services for immigration and citizenship matters and issues relating to mortgages are INELIGIBLE. Retainer fee arrangements and contingency fee arrangements are also ineligible.
     13. Credit repair - ESG funds may pay for credit counseling and other services necessary to assist program participants with critical skills related to household budgeting, managing money, accessing a free personal credit report, and resolving personal credit problems. This assistance does not include the payment or modification of a debt.

Short-Term and Medium-Term Rental Assistance

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E. Rapid Rehousing (24 CFR §576.104)

Individuals and families who are LITERALLY homeless as defined by HUD (ONLY Category 1 & 4)

• Category 1: Literally Homeless (staying in Emergency Shelter, Safe Haven, Motel/Hotel supported with Government/Charity, Street/Place not meant for human habitation)
• Category 4: Fleeing/attempting to flee Domestic Violence (Only living in Safe Home, Shelter, or Place not meant for Human Habitation)

You can refer to this flowchart to determine whether a participant is eligible for Rapid Rehousing or Homelessness Prevention assistance. ESG Homelessness Prevention and Rapid Rehousing Eligibility Determination Flow Chart (pdf).

Overview of Eligible Activities:

Generally, the intent of Rapid Rehousing assistance is to quickly transition program participants to stability, either through their own means or through public benefits, as appropriate.

Assistance should be focused on housing stabilization, linking participants to community resources and mainstream benefits, and helping them develop a plan to prevent housing instability.

Financial Assistance:

• Short-term rental assistance (3 months)
• Medium-term rental assistance (4 to 24 months)
• Rent arrearages (up to 6 months)
• Security deposits and Utility deposits
• Utility payments (up to 18 months including up to 6 months' arrearages)
• Moving cost assistance
• Staffing and operating costs associated with implementing eligible financial assistance activities

Housing Relocation and Stabilization Services:

• Case management
• Outreach and engagement
• Landlord/Tenant Education
• Housing search and placement (includes inspections)
• Legal services
• Credit repair/Financial Counseling

NOTE: Motel/hotel vouchers are not an eligible expense under Rapid Rehousing or Homelessness Prevention assistance.

Eligible Costs: Specific eligible costs consist of the following:

Housing Relocation and Stabilization Services

1. Financial Assistance Costs - ESG funds may ONLY be used to pay housing owners, utility companies, and other third parties for the following costs (cannot pay funds directly to participant):
   1. Rental application fees - ESG can support Fee, only if Fee is charged by the owner to ALL applicants, not just participant(s) receiving assistance.
   2. Security deposits - Equal to no more than 2 months' rent.
   3. Last month's rent -
      1. If necessary to obtain housing, the last month's rent may be paid from ESG funds to the owner of that housing at the time the owner is paid the security deposit and the first month's rent.
      2. This assistance must not exceed one month's rent and MUST be included in calculating the program participant's total rental assistance, which cannot exceed 24 months during any 3-year period.
   4. Utility deposits - Only can support a utility deposit that is required by the utility company for all customers (only for gas, electric, water, and sewage).
2. Utility payments -
   1. ESG funds may pay for up to 24 months of utility payments per program participant, per service, including up to 6 months of utility payments in arrears, per service.
   2. A partial payment of a utility bill counts as one month.
   3. This assistance may only be provided if the program participant or a member of the same household has an account in their name with a utility company or proof of responsibility to make utility payments.
   4. Eligible utility services are gas, electric, water, and sewage.
   5. No program participant shall receive more than 24 months of utility assistance within any 3-year period.
3. Moving costs -
   1. ESG funds may pay for moving costs, such as truck rental or hiring a moving company.
   2. This assistance may include payment of temporary storage fees for up to 3 months, provided that the fees are accrued after the date the program participant begins receiving assistance and before the program participant moves into permanent housing.
   3. Payment of temporary storage fees in arrears is not eligible.
4. Services Costs. ESG funds may be used to pay the costs of providing the following services:
   1. Housing search and placement - Services or activities necessary to assist program participants in locating, obtaining, and retaining suitable permanent housing, include the following:
      1. Assessment of housing barriers, needs, and preferences;
      2. Development of an action plan for locating housing;
      3. Housing search;
      4. Outreach to and negotiation with owners;
      5. Assistance with submitting rental applications and understanding leases;
      6. Assessment of housing for compliance with Emergency Solutions Grant (ESG) requirements for habitability, lead-based paint, and rent reasonableness;
      7. Assistance with obtaining utilities and making moving arrangements; and
      8. Tenant counseling.
   2. Housing stability case management -
      • ESG funds may be used to pay cost of assessing, arranging, coordinating, and monitoring the delivery of individualized services to facilitate housing stability for a program participant who resides in permanent housing or to assist a program participant in overcoming immediate barriers to obtaining housing.
      • This assistance cannot exceed 30 days during the period the program participant is seeking permanent housing and cannot exceed 24 months during the period the program participant is living in permanent housing.
      • Component services and activities consist of:
        1. Using the Coordinated Entry system to evaluate participants applying for or receiving assistance;
        2. Conducting the initial evaluation, including verifying and documenting eligibility;
        3. Counseling;
        4. Developing, securing, & coordinating services/benefits;
        5. Monitoring and evaluating program participant progress;
        6. Providing information and referrals to other Subrecipients;
        7. Developing an individualized housing and service plan, including a path to permanent housing stability; and
        8. Conducting re-evaluations required under §576.401(b).
5. Mediation - ESG funds may pay for mediation between the program participant and the owner or person(s) with whom the program participant is living, provided that the mediation is necessary to prevent the program participant from losing permanent housing in which the program participant currently resides.
6. Legal services - Legal services MUST be necessary to resolve a legal problem that prevents a participant from obtaining or maintaining permanent housing. Eligible subject matters include:
   • 1. Landlord/tenant matters
     2. Child support, guardianship, paternity,emancipation, and legal separation,
     3. Orders of protection and
     4. Other civil remedies for victims of domestic violence, dating violence, sexual assault, and stalking,
     5. Appeal of veterans and public benefit claim denials, and
     6. Resolution of outstanding criminal warrants.
   • Eligible costs include hourly fees for legal advice and representation by attorneys.
   • Fees based on the actual service performed (i.e. fee for service) can only be supported with ESG funds if the cost is less than the hourly fee.
   • Other eligible costs may include participant intake, preparation of cases for trial, provisions of legal advice, representation at hearings, counseling, filing fees, and other necessary court costs.
   • Subrecipient's employees' salaries and other costs necessary to perform the services are eligible, if the subrecipient is a legal services Subrecipient and performs the services itself.
7. Credit repair - ESG funds may pay for credit counseling and other services necessary to assist program participants with critical skills related to household budgeting, managing money, accessing a free personal credit report, and resolving personal credit problems. This assistance does not include the payment or modification of a debt.

Short-Term and Medium-Term Rental Assistance

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F. Homeless Management Information System (HMIS) (24 CFR §576.107)

Eligible Program Participants:

* N/A - Not a service, but rather funds to support the operation and use of the Homeless Management Information System (HMIS)

Overview of Eligible Activities:

Homeless Management Information System (HMIS) is a locally administered, electronic data collection system that stores longitudinal person-level information about persons who access the homeless service system. Every Continuum of Care (CoC) is required to implement a HMIS to comply with HUD's data collection, management and reporting standards.

ALL ESG funded activities should have their participant level data entered into a HMIS or a comparable database (if a Domestic Violence or Legal Services Subrecipient). Any comparable databases must comply with all current HMIS rules and notices. Eligible costs under this category include usage and operation of an HMIS system and/or comparable database. For more information on HMIS requirements, please visit the HUD Exchange.

Eligible Costs: Specific eligible costs consist of the following:

HMIS Costs for Non-HMIS and HMIS Leads

1. Costs of contributing data to the HMIS designated by the Continuum of Care for the area, including the costs of:
   1. Purchasing or leasing computer hardware;
   2. Purchasing software or software licenses;
   3. Purchasing or leasing equipment, including telephones, fax machines, and furniture;
   4. Obtaining technical support;
   5. Leasing office space;
   6. Paying charges for electricity, gas, water, phone service, and high-speed data transmission necessary to operate or contribute data to the HMIS;
   7. Paying salaries for operating HMIS, including:
      1. Completing data entry;
      2. Monitoring and reviewing data quality;
      3. Completing data analysis;
      4. Reporting to the HMIS Lead;
      5. Training staff on using the HMIS or comparable database, and
      6. Implementing and complying with HMIS requirements;
   8. Paying costs of staff to travel to and attend HUD sponsored and HUD approved training on HMIS and programs;
   9. Paying staff travel costs to conduct intake; and
   10. Paying participation fees charged by the HMIS Lead, if the subrecipient is not the HMIS Lead. The HMIS Lead is the entity designated by the Continuum of Care to operate the area's HMIS.

HMIS Costs for HMIS Leads ONLY

1. If the recipient is the HMIS lead subrecipient (approved by the CoC Representative), in addition to the costs noted in the previous section, it may also use ESG funds to pay the costs of:
   1. Hosting and maintaining HMIS software or data;
   2. Backing up, recovering, or repairing HMIS software or data;
   3. Upgrading, customizing, and enhancing the HMIS;
   4. Integrating and warehousing data, including development of a data warehouse for use in aggregating data from subrecipients using multiple software systems;
   5. Administering the system;
   6. Reporting to Subrecipients, the Continuum of Care, and HUD; and
   7. Conducting training on using the system or a comparable database, including traveling to the training.

Comparable Database Costs (DV/Legal Service ONLY)

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G.  Administration (24 CFR §576.108)

Eligible Program Participants:

* N/A - Not a service, but rather funds to support the administration of the ESG program.

Overview of Eligible Activities:

Up to 7.5% of your subrecipient's annual ESG allocation may be used for administrative costs related to planning and execution of ESG activities. This does not include overhead costs directly related to carrying out eligible activities (i.e. space costs associated for Rapid Rehousing case manager, etc...).

Administrative funds must be itemized on your ESG budget, separate from your programmatic costs.

Eligible Costs: Specific eligible costs consist of the following:

1. Costs of overall program management, coordination, monitoring and evaluation, including:
   1. Salaries, wages, and related costs of staff engaged in program administration.
   2. In charging costs to this category, the subrecipient may use only one of these methods for each fiscal year grant:
      1. Include the entire salary, wages and related costs allocable to the program of each persons whose primary responsibility regarding the program involve program administration assignments, or
      2. Include the prorated share of the salary, wages and related costs of each person whose job includes any program administration assignments.
2. Preparing program budgets and schedules, and amendments to those budgets and schedules;
   1. Developing systems for assuring compliance with program requirements;
   2. Developing inter-subrecipient agreements and agreements with subrecipients and contractors to carry out program activities;
   3. Monitoring program activities for progress and compliance with program requirements;
   4. Preparing reports and other documents directly related to the program for submission to DHS or HUD;
   5. Coordinating the resolution of audit and monitoring findings;
   6. Evaluating program results against stated objectives; and
   7. Managing or supervising persons whose primary responsibilities regarding the program includes such assignments such as those described in this section.
3. Travel costs incurred for monitoring of subrecipients;
4. Administrative services performed under third-party contracts or agreements, including general legal services, accounting services, and audit services;
5. Other costs for goods and services required for administration of the program, including rental or purchase of equipment, insurance, utilities, office supplies, and rental and maintenance (but not purchase) of office space; and
6. Costs of providing training on ESG requirements and attending HUD sponsored ESG trainings (Most conferences are not HUD sponsored, including National Alliance to End Homelessness Conferences is not a HUD-sponsored).

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H.  Ineligible Activities (24 CFR §576.108)

Ineligible Costs: Specific ineligible costs consist of the following:

1. All ESG Activities
   1. Depreciation, bad debts and late fees (except under arrears for RR/HP rental assistance)
   2. Recruitment, non-HUD staff training, entertainment, non-HUD conferences, and retreats
   3. Public relations or fundraising
   4. Any activities not explicitly detailed in the regulations
   5. Payment of participant credit card or other consumer debt;
   6. Payment of participant mortgage costs and mortgage arrears;
   7. Acquisition of real property
   8. New construction
   9. Property clearance or demolition
   10. Costs associated with the organization rather than the project (advertisements, pamphlets about organization, surveys, etc.)
   11. Salary of case management supervisor when not working directly on participant issues (unless charged to administration)
   12. Advocacy, planning, and organizational capacity building
   13. Transportation costs not directly associated with service delivery (see eligible activities for specific details on eligible transportation costs)
   14. Legal Services for immigration and citizenship matters
   15. Substance abuse treatment services for inpatient detoxification and other inpatient drug or alcohol treatment
   16. Cash assistance to participants
   17. No financial assistance to a household for a purpose and time period supported by another public source (unless it is 6 months or less of arrears under RR/HP)
   18. Payment or modification of a participant credit card and other debts (excluding arrears, when supported under RR/HP)
2. Street Outreach Specific
   1. Services performed in a building or not on the street.
   2. Motel/Hotel Vouchers
   3. Any activities not explicitly detailed in the regulations
   4. Any other ineligible expenses listed above or in ESG regulations/manuals/program notices.
3. Emergency Shelter Specific
   1. Services performed on the street (those should be offered under Street Outreach).
   2. Any activities not explicitly detailed in the regulations
   3. Any other ineligible expenses listed above or in ESG regulations/manuals/program notices.
4. Rapid Rehousing Specific
   1. Services to program participants who are not LITERALLY HOMELESS under HUDs definition.
   2. Motel/Hotel Vouchers
   3. Travel costs, Car repair or transportation costs for Participants
   4. Medical or dental care and medicines
   5. Clothing, grooming, or Pet care
   6. Home furnishings
   7. Work or education related materials
   8. Payment of temporary storage fees in arrears
   9. Any activities not explicitly detailed in the regulations
   10. Any other ineligible expenses listed above or in ESG regulations/manuals/program notices.
5. Homelessness Prevention Specific
   1. Services to program participants who are not at imminent risk or at risk of HOMELESS under HUDs definition.
   2. Motel/Hotel Vouchers
   3. Travel costs, Car repair or transportation costs for Participants
   4. Medical or dental care and medicines
   5. Clothing, grooming, or Pet care
   6. Home furnishings
   7. Work or education related materials
   8. Payment of temporary storage fees in arrears
   9. Any activities not explicitly detailed in the regulations
   10. Any other ineligible expenses listed above or in ESG regulations/manuals/program notices.
6. Homeless Management Information System (HMIS) Specific
   1. Any activities not explicitly detailed in the regulations
   2. Any other ineligible expenses listed above or in ESG regulations/manuals/program notices.
7. Administration Specific
   1. Any activities not explicitly detailed in the regulations
   2. Any other ineligible expenses listed above or in ESG regulations/manuals/program notices.

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