[From the HUD Listserve]

More than three years have passed since the COVID-19 pandemic was declared a national public health emergency in January 2020 providing the federal government flexibility to waive or modify requirements in a range of programs. Numerous people have died or been hurt by the pandemic, including many who were experiencing homelessness. Federal, state, and local partners have done an unprecedented amount of work to use resources to assist people experiencing and at risk of homelessness. 

On May 11, 2023, the federal COVID-19 Public Health Emergency (PHE) Declaration ended. The bullets below highlight what the end of the PHE declaration means for those working on Continuum of Care (CoC) or Emergency Solutions Grants (ESG) programs (including ESG-CV).  

  • Waivers related to the CoC and annual ESG programs from Notice CPD-22-09 expired March 31, 2023.  
  • Notice CPD-21-08 says that” Temporary Emergency Shelter means any structure or portion of a structure, which is used during a Federal, state, or local emergency declaration, such as for a natural disaster or public health emergency, and for up to 12 months after that declaration expires, to provide shelter for individuals and families displaced from their normal place of residence or sheltered or unsheltered locations.”
    • With the end of the PHE declaration on May 11, 2023, the 12-month clock to ramp down temporary emergency shelter began.  
    • If there is a local public health emergency or a natural disaster emergency still in effect, then the 12-month wind down clock does not begin until those declarations have ended. 
  • All otherwaivers and flexibilities in place for ESG-CV (i.e. Notices CPD-22-06, CPD-21-08 and CPD-21-05) are applicable until the grant period of performance ends. 
  • The work of the ESG-CV program remains important to “to prevent, prepare for, and respond to coronavirus, among individuals and families who are homeless or receiving homeless assistance and to support additional homeless assistance and homelessness prevention activities to mitigate the impacts created by coronavirus.”   
  • The SNAPS office extended the ESG-CV expenditure deadline by one year to September 30, 2023, to allow the important work of the program to continue. It is important that recipients expend and then draw their remaining funds in a timely manner for allowable activities. If you are in need of assistance to meet the upcoming deadlines, please request HUD TA: Request Program Assistance – HUD Exchange.  

                   

Although the public health emergency is over, there is still a considerable amount of ESG-CV funds to spend (and all ESG-CV waivers are still in place as stated above). SNAPS is starting to formulate takeaways from the innovative approaches that recipients took with their CARES Act funding to inform ESG program approaches in the future. Specifically, given the limited ESG funding, how can we take ESG-CV lessons learned to make ongoing ESG programs the most effective. HUD Technical Assistance (TA) providers are working on a product that summarizes ESG-CV best practices, helps recipients reflect on their past performance, and recommends how to make decisions for moving forward with annual ESG. 

SNAPS will be publishing an ESG proposed rule that will be posted for public comment so recipients, advocates, and other stakeholders can provide feedback and to take lessons learned from ESG-CV into account in making changes to the ESG regulations.  

Additionally, it is important for CoCs and ESG recipients to reach out to their local Participating Jurisdictions (PJs) to coordinate on HOME-ARP; this is a large source of funding for rental housing and non-congregate shelter, and if the PJ’s plan involves capital costs for non-congregate shelter (NCS), they may need ESG to assist with ongoing operating costs. 

Here are a few TA products that touch on the topic of continuing the work begun under ESG-CV. 

Thank you for all you have done to prevent and end homelessness for countless households prior to COVID-19, over the course of the PHE, and in the months and years to come. 

Published by Scott Tibbitts