As you may know, late last week Congress passed and the President signed H.R. 2112, the “mini-bus” Appropriations Bill that funded federal FY 12 appropriations for HUD, USDA Rural Development, Transportation and several other agencies. As you will see from the National Low Income Housing Coalition’s extensive analysis below, most of the news for housing and community development is very bad.
Fortunately for Vermont there is a silver lining, as Senator Leahy, taking the lead for the Vermont delegation, was able to get an additional $400 million in CDBG dedicated to disaster relief. We don’t know yet how much of that Vermont will receive, but it is my understanding that we should do relatively well. Also on the good news side, HUD Housing Counseling Assistance was restored at $45 million, which brings it back up to just over 50% of the federal FY 10 funding level. This will help provide key funding for Vermont’s five HomeOwnership Centers, CVOEO’s Mobile Home Project, BROC, CVCAC and Opportunities Credit Union. The other really good news, as you have probably heard, is that the Transportation budget significantly benefits Irene recovery efforts by providing additional funds for highway disaster relief and by removing caps on federal assistance, both of which will take significant pressure off the State’s FY 13 budget.
All three member of the Congressional delegation deserve our thanks for their incredibly hard work to generate good news for Vermont amid what is otherwise a bleak federal funding picture. Please take a moment to drop delegation staff a thank you for their and their bosses’ good efforts.
I have not yet had the time to estimate the losses Vermont will sustain as a result of some of the deep cuts to key housing and community development programs. My preliminary analysis indicates that, between the State and Burlington, Vermont will lose approximately $900,000 in formula CDBG funds. That’s in addition to the $1.5 million we already lost in federal FY 11. Vermont will also lose approximately another $600,000 in HOME funds on top of the $500,000 lost in FY 11. Although H.R. 2112 adopted the generally higher Senate funding levels for the USDA Rural Development budget, it still contains deep cuts to Section 502 Single Family Direct, 515 Multi-Family, 521 Rental Assistance, and other key programs. The direct impact on Vermont of all the cuts is as yet unclear. I will work with our State funding agencies to come up with detailed estimates in the coming weeks.
In other federal news, on November 15 HUD released long-awaited regulations for the HEARTH Act, including the interim rule for the Emergency Solutions Grant (ESG) Program, the final rule on the definition of the term “homeless,” and the second allocation for FY11 ESG funds, which will yield an additional $205,000 for Vermont’s shelters and homeless assistance programs. See the NLIHC summary below for more information.
For additional information on the HUD and Rural Development budgets:
Wishing you all a great Thanksgiving
NATIONAL LOW INCOME HOUSING COALITION MEMO TO MEMBERS
November 18, 2011
***Final FY12 Budget Cuts HUD, Rural Housing Programs
On November 17, Congress passed H.R. 2112, the minibus appropriations bill that includes three spending bills: Transportation, Housing and Urban Development (T-HUD), S. 1596; Agriculture, Rural Housing, and Food and Drug Administration, H.R. 2112; and Commerce, Justice, and Science, H.R. 2596 (see Memo, 11/11). The bill underfunds HUD and Rural Housing programs, cutting many programs deeply.
The conference committee approved its report on the bill on November 14. Thirty-seven of 38 members signed, with Senator Richard Shelby (R-AL) the only dissenting vote. The House approved the conference report on November 17 by a vote of 298 to 121. Later the same day, the Senate approved the report by a vote of 70 to 30. President Barack Obama signed H.R. 2112 into law on November 18.
H.R. 2112 cuts HUD funding by $3.7 billion or 9% below FY11 funding levels, providing only a net total of $37.4 billion for HUD programs.
The bill provides $18.91 billion for the Tenant-Based Rental Assistance (TBRA) account. The bill underfunds TBRA contract renewals, providing $17.24 billion in FY12. The conference committee increased funding for this line item by $199 million over the House bill and $99 million over the Senate bill. The Center on Budget and Policy Priorities (CBPP) estimates that the bill short-funds voucher contract renewals by $93 million. The contract renewal funding falls short of HUD’s reported estimate for contract renewals by more than $130 million. This shortfall could result in the loss of between 12,000 and 24,000 vouchers, according to a November 18 report by CBPP.
Public housing agencies (PHAs) can use net restricted assets to cover voucher shortfalls. However, the bill rescinds $650 million in voucher program net restricted assets. The Senate proposed rescinding voucher funds by $750 million. HUD officials reported that a rescission of that level would have left PHAs with less reserve funding than a minimum of one month, which the Senate version of the bill set as a floor for reserve funding levels. The final bill does not include language requiring the HUD Secretary to preserve PHAs’ reserves at no less than one month.
H.R. 2112 cuts voucher administrative fees by 3% below FY11 and 1% below the President’s request. Administrative fees were also cut in FY11, and two years’ funding cuts could result in PHAs issuing turned over vouchers at a slower rate. Over time, this could result in the loss of vouchers by attrition.
While H.R. 2112 would not renew all current vouchers, consistent with the President’s request it does provide $75 million for new Veterans Affairs Supportive Housing (VASH) vouchers, or about 11,000 vouchers. This restores VASH funding to the FY10 level. In FY11, only $49 million was provided for new VASH vouchers.
Section 811 vouchers are funded at $112 million, 2% below the President’s request. In FY11, $114 million was provided for rental assistance in the Section 811 program, in part through the Section 811 account and in part through the TBRA account. In FY12, the full amount of rental assistance for the Section 811 program will be provided through TBRA vouchers.
The bill also provides $60 million for the Family Self-Sufficiency program, the amount requested by the President and level with FY11 funding. Tenant Protection vouchers are funded at $75 million, a 32% cut below FY11 but consistent with the Administration’s FY12 request. The bill provides a $10 million set-aside to provide Tenant Protection Vouchers to a wider population of tenants who would otherwise lose their affordable units (see article elsewhere in Memo). This provision was included in the Senate bill.
For the second consecutive year, the bill does not include funding for Homeless Demonstration Vouchers. The demonstration was funded in the Senate bill at $5 million but the House bill did not provide funding. The President requested $57 million for the program in FY12 and $85 million in FY11.
Project-Based Section 8
The Project-Based Rental Assistance (PBRA) program is funded at $9.34 billion, an amount lower than both the House Subcommittee and Senate-passed bills. The bill also rescinds $200 million from the Housing Certificate Fund used to supplement the PBRA contracts. HUD says that funding provided in the bill will allow it to renew all project-based contracts for 12 months.
The Public Housing Capital Fund is severely underfunded by H.R. 2112 at only $1.88 billion. This is 8% below the FY11 level and 22% below the President’s FY12 request. HUD calculates that public housing capital needs exceed $25 billion. The bill’s FY12 funding will limit PHAs’ ability to address even capital needs that will occur in the current fiscal year, which would cost $3.4 billion in FY12. Thousands of public housing residents will be at risk of living in substandard housing and tens of thousands of public housing units may be lost due to neglected capital repairs.
The bill provides $3.96 billion for the Public Housing Operating Fund but relies on HUD to offset the full amount of FY12 operating costs through PHA reserves. The bill authorizes HUD to offset no more than $750 million in reserve funding to supplement the operating fund. Although the House Subcommittee bill would have prohibited funding state public housing units that were converted to federal units with funding from the American Recovery and Reinvestment Act (ARRA), this provision was not included in the final bill. The bill also imposes new restrictions on PHA employee salaries that can be paid with funds from this bill.
The Choice Neighborhoods Initiative is funded at $120 million, 52% below the President’s requested funding level. In FY11, CNI was funded at $65 million as a set-aside within the HOPE VI account. The House subcommittee bill did not provide funding for either the HOPE VI program or CNI. The Senate bill provided $120 million for CNI and no funding for HOPE VI. The final bill includes no funding for HOPE VI but does require that at least $80 million of the $120 million of CNI funds go to PHAs.
Homeless Assistance Grants are level-funded at the FY11 level of $1.9 billion, 20% below the President’s FY12 request. Funding at this level will not allow HUD to fully enact HEARTH, for which HUD has just issued new rules (see article elsewhere in Memo). By not funding Homeless Assistance Grants at the level the President requested, at least 492,000 households experiencing homelessness will not receive housing assistance. On November 14, before the Conference report was issued, 47 members of the House of Representatives sent a letter to the T-HUD Appropriations Subcommittee Chair Tom Latham (R-IA) and Ranking Member John Olver (D-MA) urging them to increase funding for Homeless Assistance Grants in the conference report.
The most severe cut was to the HOME Investments Partnership program, the subject of investigation by the Washington Post and hearings in the House Financial Services Committee (see Memo, 5/20, 6/3, 11/4). HOME was cut to $1 billion from $1.6 billion in FY11, a 38% cut. Based on HUD’s latest public data on affordable housing units constructed from FY10, this cut will result in 31,000 fewer affordable homes, which could include over 9,000 affordable rental units and nearly 8,000 fewer rental subsidies.
The bill includes new oversight and monitoring requirements for the HOME program. One requires that homeownership units that are not sold within six months of a project’s completion be turned into rental units. Another provision sets a four-year limit on the length of time between commitment of funds and project completion. If a project is not completes within four years, the funds are to be repaid, although HUD would have flexibility to approve a one-year extension.
The bill cuts the Section 202 Housing for the Elderly program by 51% below the President’s funding level, funding Section 202 at $374 million. While this is only 6% below the FY11 funding level, the program was cut last year and the FY12 funding level is 55% below the FY10 level. The bill does not provide enough funding for new construction, which could mean 2,500 to 3,000 new units for elderly households will not be developed.
The Section 811 Housing for Persons with Disabilities program is increased by 10% over FY11 funding to $165 million, partially restoring cuts made in FY11. The final bill directs the HUD Secretary to conduct the Project Rental Assistance Demonstration as authorized by 2010’s Frank Melville Supportive Housing Investment Act. Under the demonstration, developers can combine rental assistance from Section 811 and other capital subsidy programs, making it easier to provide supportive housing within developments and increase the number of units provided through Section 811.
The Housing Opportunities for Persons with AIDS (HOPWA) program is cut to $332 million, slightly below both the FY11 funding level of $334 million and the President’s request of $335 million.
Community Development Fund
The bill cuts the Community Development Fund to $3.3 billion, 6% below FY11 and 13% below the President’s request. The Community Development Block Grant (CDBG) formula grants are cut to $2.95 billion, 12% below FY11 funding and 20% below the President’s request. The Senate bill would have provided funding for a Sustainable Communities Initiative, Regional Integrated Planning Grants and Community Challenge Grants, but the final bill drops these provisions. It does include provisions from House bill that prohibits CDF funding for the Economic Development Initiative and the Rural Innovation Fund. The bill allows 20% of CDBG funding to be used for administrative, planning and management purposes, consistent with prior years and with the Senate bill. The House bill would have reduced administrative funding to 10%. The House bill also would have provided $7 million for use in insular areas but this provision was dropped from the final bill.
The bill also provides $400 million for emergency disaster grants. This funding was added to the Senate bill through an amendment offered in the Appropriations Committee mark up and was originally was not funded from within the HUD bill. The Conference Committee, however, decided to offset $300 million of this funding from within the T-HUD bill in the CDBG account.
Other HUD Programs
Funding for the Housing Counseling program is partially restored to $45 million, 49% below the President’s request. All funding for counseling was cut in FY11.
The Self-Help Homeownership Opportunity Program (SHOP) is funded at $13 million, 50% below FY11. The President’s budget did not include funding for the program in FY12. The Native American Housing Block Grant was level funded at $650 million, 7% below the President’s request. The Native Hawaiian Housing Block Grant was level funded at $13 million, a 30% increase over the President’s request.
The Healthy Housing and Lead Hazard account is funded at $120 million, slightly above FY11 funding but 14% below the President’s request of $140 million. The Healthy Homes Initiatives grants are funded at $10 million, 50% below the FY11 level. The bill includes language requiring that grant applicants for areas with the highest lead paint abatement needs certify they have adequate capacity to carry out grant activities.
The Fair Housing and Equal Opportunity program is funded at $70.8 million, 1% below FY11 funding and 2% below the President’s request. The Fair Housing Initiatives Program grants are funded at $42.5 million, consistent with FY11 funding and the President’s request. The bill also includes funding for Fair Housing limited English proficiency activities, a provision that was not included in the House bill.
HUD’s Policy and Research Development funding is cut by 4% below FY11 funding levels and 19% below the President’s request. The bill also newly requires a minimum 50% match for any cooperative agreements for policy and research activities funded with non-HUD funds.
Rural Housing Services
H.R. 2112 reduces Rural Housing funding for rental programs below the FY11 funding level. Section 521 Rural Rental Assistance is funded at $904 million, slightly below the President’s FY12 requested funding level, but a cut of 5% below FY11. The Section 515 Rural Rental Housing program is funded at $64.5 million, 32% below the President’s FY12 request and a 7% cut below FY11 funding.
H.R. 2112 does include several positive HUD policy provisions including a Rental Assistance Demonstration, expanded use of tenant protection vouchers and preservation provisions (see next article in Memo).
View the H.R. 2112 Conference Report: http://www.gpo.gov/fdsys/pkg/CREC-2011-11-14/pdf/CREC-2011-11-14-pt1-PgH7433-3.pdf#page=1
View CBPP’s report: http://www.cbpp.org/files/11-18-11-IPmemoHUDapprops.pdf
View the Homeless Assistance Letter: http://nlihc.org/doc/House_Homeless_Assistance_Ltr_11-14-11.pdf
***FY12 HUD Bill Includes Important Policy Provisions
Rental Assistance Demonstration in Final FY12 Bill
The FY12 conference agreement authorizes a Rental Assistance Demonstration (RAD), requested as part of the Administration’s FY12 budget. A version was included in the Senate’s FY12 T-HUD bill, S. 1596 (see Memo, 9/23). The version of RAD in the final bill, H.R. 2112, includes some important improvements to the Senate’s language, which aligns RAD more closely with the Senate’s intent as spelled out in the report on S. 1596, with HUD’s RAD language circulated in August (see Memo, 8/26), and with NLIHC’s priorities for RAD. On November 3, NLIHC Board Member Charles Elsesser testified in support of HUD’s RAD language at a hearing of the House Financial Services Subcommittee on Insurance, Housing and Community Opportunity (see Memo, 11/4).The final bill’s RAD language includes moderate rehabilitation (mod rehab) properties in the RAD demonstration, which is capped at 60,000 public housing and mod rehab units that apply to HUD for conversion of current assistance streams to project-based Section 8 contracts or project-based vouchers by September 30, 2015.
NLIHC asked that the Senate-passed RAD language be improved in the areas of resident rights and protections, public ownership and long-term contract renewals. The report to the Senate-passed T-HUD bill made clear that each of these areas was a priority for RAD. The final RAD bill language responds to NLIHC’s concerns by assuring additional resident protections, providing more clarity on who can own converted units, including after foreclosure or bankruptcy, and providing explicit language that HUD must offer, and the owner must accept, contract renewals.
The final RAD language also includes provisions to help preserve Rent Supplement and Rental Assistance Payment properties (see description in Assisted Housing Preservation Provisions, below).
Assisted Housing Preservation Provisions
Mark to Market Extension
The final bill extends the authority of the Mark to Market program until September 30, 2015. Mark to Market authority provides owners of assisted housing the ability to restructure assisted mortgage loans when rents are marked down to market levels. Without the extension of this authority, the requirement to mark rents to market would have remained, but the authority to restructure mortgage loans so that new lower rents would cover the financing would have expired. Mark to Market extension was in the Senate’s T-HUD bill.
Tenant Protection Vouchers for Certain Unassisted HUD Tenants Facing Expiring Use Restrictions
The final bill includes the Senate bill’s $10 million set-aside of the voucher renewal account’s funds for Tenant Protection Vouchers or Enhanced Vouchers to at-risk tenants in buildings with expiring mortgages or use restrictions who are not now eligible for assistance. Advocates in Illinois, Massachusetts and across the nation worked closely with Senators Richard Durbin (D-IL) and Scott Brown (R-MA), who advocated for these protections.
The National Housing Trust estimates that in FY12 alone, almost 13,000 affordable housing units nationwide, financed through various HUD-subsidized mortgage programs, face expiring restrictions, but tenants are not covered by project-based Section 8 contracts. These tenants do not qualify for any tenant protection assistance when these HUD-subsidized mortgages mature or certain non-renewable rental assistance contracts expire.
The final FY12 HUD language would provide tenant protection assistance, through Tenant Protection Vouchers or Enhanced Vouchers, to tenants in these properties if they are in low-vacancy areas and may have to pay rents greater than 30% of household income. This tenant protection assistance could also be utilized as project-based vouchers. HUD must issue implementation guidelines by mid-March.
Project-Basing Tenant Protection Vouchers
The final T-HUD bill also includes an amendment, championed by Senators Jeff Merkley (D-OR) and Scott Brown (R-MA), to authorize project-based vouchers in lieu of tenant-based vouchers that would otherwise be issued for expiration of a Rent Supplement (Rent Supp), Section 236 Rental Assistance Payment (RAP), or Section 8 mod rehab contract.
Eligibility to project-base these tenant protection vouchers is limited to Rent Supp, RAP or mod rehab projects that converted to vouchers since October 1, 2006, or will do so in the future. HUD must issue guidelines that include tenant consultation and the agreement of a housing authority administrator. This authority was included under the bill’s Rental Assistance Demonstration but will only be in effect in FY12 and FY13. In FY12 alone, HUD is expected to issue about 2,000 tenant protection vouchers for expiring Rent Supp and RAP tenants. This amendment will ensure these and other tenants have affordable housing, and that these homes are affordable for the long-term.
Any project-based vouchers issued under this provision will not count toward a public housing agency’s 25% limit on the number of housing choice vouchers it may project-base.
Schumer Amendment to Retain Project-Based Assistance
The T-HUD appropriations bill has included the “Schumer Amendment” for several years. The language, spearheaded by Senator Charles Schumer (D-NY), requires the HUD Secretary to preserve project-based contracts on troubled properties before or during the foreclosure process. The Schumer amendment language is improved in FY12. The requirement now applies to all project-based contracts, not just those on HUD-insured or HUD-held properties Also, prior to abating a contract and relocating tenants for health and safety threats, HUD must provide notice to tenants and obtain tenant consent, and first use other available remedies, including partial abatements and receivership.
Transfer of Project-Based Assistance
The T-HUD bill includes revised language authorizing the HUD Secretary to transfer some or all project-based assistance, debt, and use restrictions from one multifamily project to another multifamily project or projects. The FY12 T-HUD bill includes a new provision here, allowing the transfer to be done in phases to accommodate financing and other requirements related to rehabilitating or constructing the project or projects to which the assistance will be transferred. New language also allows the number of units in the property receiving the transferred assistance to be fewer than at the original property if those units were unoccupied and the reduction is needed to reconfigure bedroom sizes to meet current market demands. The FY12 T-HUD language also brings Section 811 properties under this overall transfer authority.
SEVRA Changes Not Included
The final FY12 HUD bill does not include rent simplification provisions sought by HUD in its FY12 budget request (see Memo, 2/18). HUD requested the FY12 bill include cost-saving provisions from earlier Section 8 Voucher Reform bills. These included changing the definition of extremely low income (ELI), which, in effect, would have modified the current income targeting for public housing, voucher, and project-based assistance program eligibility. The new definition of ELI would have been the higher of the national poverty level, adjusted for family size, or 30% of area median family income.
The Administration’s FY12 request would have also raised the standard deduction for elderly and disabled families from $400 to $675, while raising the threshold for medical and handicapped assistance expense deductions for the purpose of determining rents, from 3% to 10% of a family’s annual net income. The FY12 request would have also given the HUD Secretary the authority to conduct “rent policy demonstrations.” HUD’s FY12 request also sought to change how fair market rents (FMRs) are developed, adopted, and used.
Moving to Work Expansion Not Included
The final FY12 bill does not give the HUD Secretary the authority to extend the Moving to Work demonstration to any new agencies, as have recent HUD appropriations bills.
Student Fees and Program Eligibility
Led by Senator Tom Harkin (D-IA), Congress changed the rules regarding college students living in Section 8 housing to address widespread concerns that student athletes with significant scholarships, including housing allowances, were living in HUD-subsidized housing. Among other changes to ensure low income students truly in need of assistance have access to it, the new law says that financial assistance in excess of tuition will be included in the student’s annual income when determining a student’s eligibility for Section 8 assistance (unless the student is older than 23 and has dependent children). The FY12 bill expands “tuition” and says that financial assistance in excess of tuition and “any other required fees or charges” will be included in a student’s income for purposes of eligibility. Congress wants to protect low income students with high required fees associated with college costs.
***HUD Releases HEARTH Act Regulations
HUD released the interim rule for the Emergency Solutions Grant (ESG) Program, the final rule on the definition of the term “homeless,” and the second allocation for FY11 ESG funds on November 15. Both of the rules reflect changes included in the Homeless Emergency Assistance and Rapid Transition to Housing (HEARTH) Act of 2009. Other Continuum of Care program and Rural Housing Stability program regulations related to the HEARTH Act will be released at a later date.
NLIHC submitted comments about the proposed homeless definition rule on June 21, 2010 (see Memo, 6/25/10). HUD, in the proposed rule, defined “persistent instability” as having moved three or more times over a 90 day period. NLIHC recommended that HUD instead use the standard of two moves over a one year time period. The final rule defines persistent instability as two or more moves over a 60 day period. HUD has also clarified that it would consider “the move out of the initial permanent housing placement as the first move.”
NLIHC, in its comments on the proposed rule, recommended that an oral statement alone be considered acceptable evidence of homeless status. In the final rule HUD says that third-party documentation is the preferred method of confirmation of homeless status: “HUD revised paragraph (b) of the recordkeeping requirements for ‘homeless status’ to clarify that the order of priority among documentation is third-party documentation first, intake worker observation second, and certification by the individual or head of household seeking assistance third.”
With respect to the documentation of an individual’s stay in an institution, HUD says that the final rule “expands what is an acceptable evidence of an individual’s stay in an institution to include an oral statement.”
The HEARTH Act replaced the Emergency Shelter Grant program with the Emergency Solutions Grant program. The new ESG program includes an emphasis on homelessness prevention and rapid re-housing and the rule incorporates many provisions from the temporary Homelessness Prevention and Rapid Re-housing program (HPRP). Under the prevention and rapid re-housing provisions of the regulations, HUD clarifies that ESG funds may be used for many expenses related to housing stabilization including security deposits, last month’s rent, moving costs, housing search and placement, and housing stability case management. The interim ESG regulation includes corresponding amendments to HUD’s consolidated planning requirements.
HUD summarizes the major changes in the ESG program as “the addition of an annual funding cap on street outreach and emergency shelter activities; clarification of the eligible costs for street outreach and emergency shelter activities; the expansion of the homelessness prevention component of the program and the addition of a new rapid re-housing component, which both include rental assistance and housing relocation and stabilization services; expansion of the range of eligible administrative costs; and the addition of a new category of eligible activities for Homeless Management Information Systems (HMIS).”
The interim rule also includes a new requirement for ESG fund recipients to consult and coordinate with their local Continua of Care (CoC) in the allocation of funds, the creation of performance standards, and the evaluation of ESG project outcomes.
HUD notes in the introduction to the interim rule that the forthcoming proposed CoC rule will include requirements for a centralized and coordinated assessment system to evaluate initial eligibility for individuals and families who seek homeless services or homeless prevention services.
The interim rule also revises portions of Consolidated Plan (ConPlan) regulations to reflect the HEARTH Act by standardizing the homelessness elements affecting all jurisdictions required to submit a ConPlan and those applying for ESG. The changes are intended to foster closer coordination between not only ESG and CoC programs, but other mainstream housing and service programs as well.
When preparing the ConPlan five-year Strategic Plan and each subsequent Annual Action Plan allocating ESG funds, jurisdictions are now required to consult with:
- Continuum of Care in the jurisdiction’s geographic area.
- Public and private agencies that address homeless veterans and youth.
- Publicly funded institutions of care that may discharge people into homelessness.
The Citizen Participation segment of the ConPlan rule now requires jurisdictions to encourage participation by Continua of Care in the process of developing and implementing the ConPlan.
The ConPlan rule broadens attention beyond chronically homeless people to include families with children, veterans and their families, and unaccompanied youth.
The “Housing Needs Assessment” component of the ConPlan adds a new category of person whose housing assistance needs must be assessed by jurisdictions: formerly homeless families and individuals who are receiving rapid re-housing assistance that will soon end.
The “Housing Market Assessment” must include an inventory of mainstream services, not just homeless services, to stress the importance of using and collaborating with mainstream assistance providers to prevent and end homelessness.
The Strategic Plan and Annual Action Plan portions of the ConPlan now requires a jurisdiction to describe its strategies for reducing and ending homelessness by helping homeless people transition to permanent housing by shortening the period of time people are homeless, helping them gain access to affordable housing, and preventing people who were recently homeless from becoming homeless again. Jurisdictions must also describe strategies for helping people avoid homelessness, especially those likely to become homeless after being discharged from publicly funded institutions and systems of care.
The interim ESG rule is available at http://www.hudhre.info/index.cfm?do=viewResource&ResourceId=4517
The final homeless definition rule is available at http://www.hudhre.info/index.cfm?do=viewResource&ResourceID=4519
The ESG fund allocation information is available at http://www.hudhre.info/index.cfm?do=viewResource&ResourceId=4518
NLIHC’s comments on the proposed homeless definition rule are available at http://www.nlihc.org/doc/NLIHC-Comments-HEARTH-Home-Def.pdf