HUD AAQ #95763: Homeless Prevention Requirement for Coordinated Entry

Question Related To: Continuum of Care Program

Question ID: 95763

Question Subject: Homeless Prevention Requirement for Coordinated Entry

Question Text:
Can you confirm that homeless prevention services only need to be a part of our Coordinated Entry if they are funded by ESG?  Basically, we need clarification that non-ESG funded homeless prevention services are not required to be part of Coordinated Entry.  We realize it is most likely strongly encouraged to include all homeless prevention projects, but we may not have that component ready for our non-ESG homeless prevention projects by the 1/23/18 deadline.  Listed below is section II.B.8 from the Coordinated Entry Notice.  I can clearly see where it states the ESG HP requirement, but the speaker on the HUD Webinar on 3/20 did not clearly say ESG when referring to homeless prevention.

• Homelessness prevention services. Persons must be able to access homelessness prevention services funded with ESG Program funds through the coordinated entry process. The coordinated entry process may include separate access point(s) for homelessness prevention so that people at risk of homelessness can receive urgent services when and where they are needed, e.g. on-site at a courthouse or hospital, provided that the separate access point(s) meet all requirements in II.B.2 of this Notice. Written policies and procedures must describe the process by which persons will be prioritized for referrals to homelessness prevention services. To the extent that other homelessness prevention programs participate in the coordinated entry process, the policies and procedures must also describe the process by which persons will be prioritized for referrals to these programs.

Response:
Thank you for submitting your question.  It appears you are seeking clarification about whether non-ESG-funded prevention projects need to participate in your CoC’s coordinated entry system.  HUD's Notice Establishing Additional Requirements for a Continuum of Care Centralized or Coordinated Assessment System, Section II.B.2, establishes that CoCs may establish separate access points for persons at risk of homelessness.  Section II.B.8 further establishes that homelessness prevention services funded with ESG Program funds must be accessible to prospective participants via the CoC’s coordinated entry process.  HUD does not have authorizing jurisdiction over prevention programs administered by non-HUD funded sources.  However, and as you have stated, CoCs are strongly encouraged to incorporate all homelessness prevention programs regardless of funding source into the CoC’s coordinated entry process.