HUD Guidance on Sub-awarding Homeless Assistance Funds to PHAs and Local Redevelopment Authorities

Today, the HUD Office of Community Planning and Development (CPD) published a new notice (CPD-17-01) that provides guidance on how Emergency Solutions Grants (ESG) Program funds can be sub-awarded to Public Housing Agencies (PHAs) and Local Redevelopment Authorities (LRAs). On July 29, 2016, President Obama signed into law the Housing Opportunity Through Modernization Act of 2016 (HOTMA) which included language, first proposed by NAHRO, that amended the McKinney-Vento Homeless Assistance Act (42 U.S. 11373(C)) to permit local governments receiving ESG funding to sub-award their ESG funds to PHAs and LRAs for eligible ESG activities. This change saves grantees from having to go through a costly and time-consuming procurement process if they wish to devolve their funds to any PHA or LRA. This change became effective upon enactment of HOTMA last year and required no regulatory rulemaking. This new notice provides additional guidance on the allowable sub-awards to PHAs and LRAs and the key requirements (e.g. consistency with the Consolidated Plan) that apply to sub-awarded funds