Addenda II
2017 ESG RFA
Response to written questions
1. What is the match requirement for the ESG RFA?
The requirements for matching ESG funds are described in section 576.201 of the ESG Interim Rule, and the requirements for documenting matching contributions are described in section 576.500(o).
In general, ESG requires 100% match, meaning if a respondent is requesting $100,000 in eligible costs, they have to show $100,000 in match. Federal (other than ESG), state, local, or private funds may be used to satisfy the requirement that the recipient provide matching contributions to ESG, so long as the following conditions are met:
· The matching funds are contributed to the ESG program and expended for the recipient or subrecipients allowable ESG costs.
· If the matching funds are from another federal program, there is no specific statutory prohibition on using those funds as match.
· The matching funds are used in accordance with all requirements that apply to ESG grant funds, except for the expenditure limits in 24 CFR 576.100. This includes requirements such as documentation requirements, eligibility requirements, and eligible costs.
· The matching funds are expended (that is, the allowable cost is incurred) after the date HUD signs the grant agreement for the ESG funds being matched.
· The matching funds are expended by the expenditure deadline that applies to the ESG funds being matched.
· The matching funds have not been and will not be used to match any other Federal program’s funds nor any other ESG grant.
· The recipient does not use ESG funds to meet the other program's matching requirements.
· The recipient keeps records of the source and use of the matching funds, including the particular fiscal year ESG grant for which the matching contribution is counted.
Note: because the matching funds are contributed to the ESG program and expended for the recipient or subrecipients allowable ESG costs, the following are not allowed to be used as match:
· SNAP benefits (food stamps), because the funds are being used to cover the program participant’s costs;
· Housing Choice Vouchers, because the funds are used to pay the PHA’s obligations under its Housing Assistance Payment contract with the owner; and
· The tenant’s portion of the rent, because this amount is the tenant’s obligation.
Also, please also note the following:
· HUD’s matching requirement is passed on to subrecipients.
· The matching funds are provided based on the total grant amount and do not have to be provided on a component-by-component basis. For example, if a recipient is spending $10,000 on HMIS, they do not need to find $10,000 in data collection funds from another source to use as match.
· HOME-TBRA funds generally cannot be used as match, because the requirements for rental assistance are significantly different between the two programs. There could be a rare instance where it is possible; if you believe this is the case, please contact HUD to see if it would be allowable.
· SHP funds generally cannot be used as match, because very few activity costs are allowable under both SHP and ESG. However, in some cases, such as where SHP funds are used for HMIS or street outreach costs that are allowable under ESG, SHP funds can be counted as match in accordance with conditions 1-8 above. Please note, however, that HMIS costs are only eligible to be used as match under ESG if they are eligible under section 576.107 and allocable to the ESG program, whether charged as direct costs or indirect costs. If the SHP HMIS funds are being used to pay for SHP projects’ data entry, those data entry costs are not allocable to the ESG program and the funds used cannot be counted as match.
2. If we have not done Rapid Rehousing for more than 9 years, can this previous experience deem us eligible to provide the service now?
You may and should use your experience with RRH as part of your response to the solicitation.
3. Can we apply to offer homeless prevention and rapid rehousing? The application asks us to pick just one.
Your application may include both HP and RRH. HP should not exceed 25% of the rental assisted requested.
4. Does the Homeless Trust allow us to use their dollars as match?
Yes, in general, local funds may be used to satisfy the requirement that the recipient
provide matching contributions to ESG.
5. If it can be used as match, under which circumstances and categories? For example, the Homeless Trust is paying for regular operations of our facility, such as salaries, utilities, general liability, etc. Can we claim those expenses as match? Or can we claim just expenses related to the direct dollars given to a client so that they can be housed.
So long as the matching funds are contributed to the ESG program and expended for the recipient or subrecipient’s allowable ESG costs (outreach, shelter and rental assistance).
6. Can a client be at our shelter and be on a waiting list to be housed under ESG? Can that time be claimed as match?
Shelter expenses not paid for by ESG may be used as a source of match.
7. Can a family receiving rapid rehousing funds from Homeless Trust also receive ESG funds?
A family who received RRH through CoC resources may be assisted with ESG Homeless Prevention if they face a new financial hardship, and are facing homelessness, so long as the total rental assistance provided does not exceed 24 months during a three year period.
A family who received RRH through CoC resources may be assisted with ESG RRH so long as the total assistance provided does not exceed 24 months during a three year period.
8. Page 7 says 7.5% of admin funds are available with 3.75 to sub recipient and 3.75 to homeless trust. But it refers to the collaborative application. Does this admin apply to the ESG grant?
The RFA was corrected to state “HUD ESG administrative funds, seven and a half percent (7.5%), will be split 50/50 with the agency(ies) funded through this solicitation and the Homeless Trust. When completing the budget, please make sure to use the 7.5% administrative funding amount indicated.”
9. The rfp page 10 says Attach 26 does not need to be returned with the application. But the ESG checklist shows attach 26 as a required form to turn in. Is this an error?
The checklist was corrected to show Attachment 26 is not a required attachment forming part of the respondent’s application.