Substantial Amendment Process for Second Allocation of

FY 2011 ESG FundsFY 2011 ESG FundsJanuary 26 2012January 26, 2012

Presenters: Resource Advisors:Mike RoanhouseSusan ZiffLindsey Stillman

Brett GagnonChuck Kieffer

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Webinar Format, Materials & Evaluation

• Webinar will last approximately ninety minutes

• A recorded version of this can be found on HUD’s Homelessness Resource Exchange at http://hudhre info within approximately 2 weekshttp://hudhre.info within approximately 2 weeks.

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Submitting Questions in the Webinar

• Audience members are muted due to the high number of participantsnumber of participants

• For audio, please use the telephone, not your computercomputer

• If you have technical difficulty with the audio or video portions of this webcast, try:video portions of this webcast, try: – Logging off, then logging in again

Requesting help through the “questions”

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– Requesting help through the questions function in the “Go To Webinar” toolbar

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Submitting Questions in the Webinar

• To pose a question for the ESG Resource Advisors during this webinar use theAdvisors during this webinar, use the “Questions” function in the “GoToWebinar” toolbar

• ESG resource advisors will only have time to answer some questions

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Submitting Questions After Webinar

• If you have a question that is not answered during the webinar you may submit it toduring the webinar, you may submit it to HUD’s Virtual Help Desk at http://hudhre.info/helpdeskp p– Select “Emergency Solutions Grants” as

your Program/System – Select “Consolidated Plan” as your sub-

topic

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Webinar Objectives

Upon completing this webinar, you will be able to:be able to:• Describe key requirements associated with

spending the second allocation of fundsspending the second allocation of funds• Describe how to calculate the expenditure

limit for emergency shelter and streetlimit for emergency shelter and street outreach activities

• Understand requirements for receiving the

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Understand requirements for receiving the second allocation of FY 2011 ESG funds

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Purpose of ConPlan Regulation Changes

• Align requirements with major goals established in HUD Strategic Plan and Opening Doors: g gFederal Strategic Plan to End Homelessness

• Align Consolidated Plan standards with gContinuum of Care Performance Standards

• Reflect statutory and regulatory standards in ESG y g yInterim Rule

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FY2011 Second Allocation

• Second allocation of FY2011 Emergency Solutions Grants Program funds released, at $90 gmillion

• Total FY 2011 ESG Allocation = $250 million• To receive funds, recipients must prepare, and

obtain HUD approval of, a substantial pp ,amendment to their FY2011 Consolidated Plan Annual Action Plan

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ESG Process Overview/Timeline

• Substantial Amendment Deadline: May 15, 2012

• HUD approves substantial amendment within 45 days (regular process)

• HUD does an amendment to the FY11 grant agreement.

Only once both parties have signed grant agreement amendment can the recipient spend

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agreement amendment can the recipient spend funds!

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ESG Process Overview/Timeline

Obligation & Expenditure Deadlines:• States:

– 60 days to obligate funds to subrecipients (for 2nd

allocation of funds, this is 60 days from date HUD signed grant agreement amendment)signed grant agreement amendment)

– Then, any subrecipients that are local governments have 120 days to obligate funds (to any non-profits or y g ( y pdesignate the local gov’t department to administer)

• Metropolitan cities, urban counties, and territories:

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– Within 180 days, the recipient must obligate all of the grant amount, except the amount for its administrative costs. 10

ESG Notice Overview

ESG Notice released on January 23, 2012:• Clarifies requirements for receiving and limitations on q g

spending FY11 ESG funds• Includes requirements and guidance for establishing

expenditure limits on emergency shelter and street outreach activitiesProvides elements that must be included in• Provides elements that must be included in substantial amendment, plus optional sections

• Provides guidance on critical decisions to be made inProvides guidance on critical decisions to be made in the planning process for FY 2012 and future consolidated planning submissions

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Second Allocation Spending Requirements and Critical FundingRequirements and Critical Funding

Decisions

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ESG Funds – Key Considerations

• Increased administrative cap – 7.5% of total FY11 allocation– Intended to support increased strategic planning and

program oversight

• Shift from emergency shelter to permanent housing

– Reflected in expenditure limit on street outreach and emergency shelter activities

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Focus on Rapid Re-housing

• HUD strongly encourages jurisdictions to target new funds toward assisting individuals and families living on the streets or in emergency shelter– Effective Rapid Re-housing can transition people out of

homelessness quickly and decrease the overall number ofhomelessness quickly and decrease the overall number of people that are homeless in the community

– Homelessness prevention is difficult to strategically target and potentially inefficient in reducing homelessnessand potentially inefficient in reducing homelessness

• Rapid Re-housing should be given highest priority under ESG to ensure that existing resources –

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under ESG to ensure that existing resources within and outside the homeless assistance system – are used as efficiently as possible

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Reprogramming Funds

Recipients may re-designate funds from 1st allocation to new activities under Emergency Solutions Grants, under 3 conditions:conditions:

• These “reprogrammed” funds are subject to requirements under the Interim Rule;

• Reprogramming of funds must not violate existing contract or subgrant agreements; and

• Reprogrammed funds must be expended within 24 months after HUD signs the ORIGINAL FY 2011 grant agreement. Note: this is different from the second allocation of

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funds, which must be expended within 24 months after HUD signs AMENDED grant agreement

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Expenditure Limit: Street Outreach and Emergency Shelter Activities

• Total amount of fiscal year grant expended on street outreach and emergency shelter cannot exceed the greater of:

– 60 percent of current fiscal year grant (total FY 2011 allocation) ORallocation) OR

– Amount of FY 2010 grant funds spent on “homeless assistance” activities

• Most recipients must spend entire second allocation of ESG funds on newly eligible

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activities (i.e., Rapid Re-Housing, Prevention, HMIS, Administration)

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Expenditure Limit: Street Outreach and Emergency Shelter Activities

• If homeless assistance amount from FY 2010 is greater than 60% of the FY 2011 grant, the amount from FY 2010 will be the expenditure limit for emergency shelter and outreach activities forexpenditure limit for emergency shelter and outreach activities for the FY 2011 grant

• If recipient has already met or exceeded this limit using the first allocation of FY 2011 funds none of the entire second allocationallocation of FY 2011 funds, none of the entire second allocation can be spent on emergency shelter and outreach

• IF a recipient did not meet the limit with the first allocation, the recipient may use some of the funds from its second allocation for emergency shelter and outreach, as long as:– Total FY 2011 grant funds for the activities do not exceed the limit,

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and – All activities comply with Interim Rule

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Calculating FY 2010 Amount

• In determining the amount of FY 2010 grant funds committed for homeless assistance activities:committed for homeless assistance activities:

– Funds must have been committed between date HUD signed FY 2010 grant agreement and January 4, 2012 (effective date of Interim Rule)

– Commitments must be documented using same id d f “ bli ti ” d fi d i thevidence used for “obligation,” as defined in the

Interim Rule– “Homeless assistance activities” include all

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– Homeless assistance activities include all activities that recipients would report as homeless assistance activities in IDIS

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Documenting FY 2010 Amount

• Each recipient must notify HUD of FY 2010 funds it committed for homeless assistance activities– In writing, to local HUD field office or regional office– On or before the date the recipient submits its

substantial amendmentsubstantial amendment

• HUD strongly encourages recipients to use T bl 1 i th N ti t d l th t f FYTable 1 in the Notice to declare the amount of FY 2010 grant funds committed to homeless assistance activities (electronic version on

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assistance activities (electronic version on www.hudhre.info/esg)

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Table 1: FY 2010 Obligations

In filling out this table:– These categories should reflect the categories reported in IDIS– The amounts in the 3 categories must equal the recipient’s

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– The amounts in the 3 categories must equal the recipient s total FY 2010 grant amount

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Documenting FY 2010 Amount• Evidence of allocation/obligation includes:

– Subgrant agreementLetter of award requiring payment from a grant to a subrecipient– Letter of award requiring payment from a grant to a subrecipient

– Procurement contract*– Written designation of a department within the government of the

i i t t di tl t li ibl ti it *recipient to directly carry out an eligible activity*– Agreement with, or letter of award requiring payment to, a

member government that has designated a department to directly t li ibl ti it **carry out an eligible activity**

* Metropolitan cities, urban counties, and territories only**Urban counties only

R i i t d t d t b it thi d t ti b t

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• Recipients do not need to submit this documentation but should be prepared to support the amounts declared when HUD requests it

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Quiz: Expenditure Limit for Shelter and Outreach

1. The expenditure limit for emergency shelter & street outreach is based on FY2010 homeless

i t ti iti bli tiassistance activities obligation.

True False

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Substantial Amendment Requirements

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Substantial Amendment Preparation

• Substantial amendments submitted pursuant to this Notice must be submitted in compliance with amended 24 CFR: Part 91 and the recipient’s established citizen participation plan

• HUD will not allow communities to shorten the planning and public comment process

• Must follow consultation requirements in preparing the substantial amendment (91 100(d) and 91 110(e))

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(91.100(d) and 91.110(e)).

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Substantial Amendment: Overview

• HUD encourages recipients to pay special attention to the following sections whenattention to the following sections when preparing the substantial amendment

Table 2: Relevant Requirements for the Substantial Amendmentab e e e a t equ e e ts o t e Substa t a e d e t

Local Governments and Territories

States

Consultation 24 CFR 91.100(d) 24 CFR 91.110(e)

Citizen Participation 24 CFR 91.105(c), (k) 24 CFR 91.115 (c), (i)

Action Plan 24 CFR 91.220(a), (c), (d), (e), (l)(4)

24 CFR 91.320(a), (c), (d), (e), (k)(3)

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Certifications 24 CFR 91.225(c) 24 CFR 91.325(c)

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Substantial Amendment Components• Substantial amendment must address the following:

– SF-424 – Summary of Consultation ProcessSummary of Consultation Process– Summary of Citizen Participation Process– Matching Resources

Proposed Activities and Overall Budget– Proposed Activities and Overall Budget– Written Standards for Provision of ESG Assistance – Process for Making Sub-awards– Homeless Participation Requirement– Performance Standards– Certifications

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– Any optional elements• Appendix B provides a summary/checklist

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Consultation Requirement

• Interim Rule directs jurisdictions to consult with:– Continuums of Care serving the jurisdictiong j– Public and private service agencies – Publicly-funded institutions and systems of care

that may discharge persons into homelessness– Business and civic leaders

P t t ll b ti b t ESG• Promotes greater collaboration between ESG recipients and Continuums of Care

• Focus on planning funding implementing and• Focus on planning, funding, implementing and evaluating homeless assistance and prevention programs locally

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Consultation Requirement

• Substantial amendment must summarize the recipient’s consultation process with CoC(s) ( )used to:

– Determine how to allocate ESG assistance for li ibl ti itieligible activities;

– Develop written performance standards for, and evaluate the outcomes of, projects and activitiesevaluate the outcomes of, projects and activities assisted by ESG funds; and

– Develop funding, policies, and procedures for the ti d d i i t ti f th HMIS

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operation and administration of the HMIS.

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Citizen Participation Requirements

• Recipients must follow their citizen participation plan when completing their substantial amendment– Includes the Interim Rule’s new citizen participation

requirements at § 91.105(a)(2)(ii) for local governments and territories and at § 91 115(a)(2)(ii) for statesand territories and at § 91.115(a)(2)(ii) for states

– Requirements list specific organizations that should be encouraged to participate in the development and implementation of the consolidated plan

• Submission must summarize the citizen participation process used in preparing the substantial amendment

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process used in preparing the substantial amendment

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Match Requirement

• All recipients must match the second allocation with an equal amount of other federal, state and local resources (cash and non-cash)– Must follow revised matching requirements (24 CFR

576 201)576.201)– Must specify the types, amounts, and proposed uses

of match in Substantial Amendmentof match in Substantial Amendment• Matching requirement does not apply to

territories

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• States must match 100% of the full second allocation amount

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Match Requirement

• Match can include cash or non-cash resources provided at any time after HUD signed the initial grant agreement; hhowever:– Resources must be used and reported in accordance with

Interim Rule’s requirements q– Match must have been used for eligible activities, based

on Interim Rule**FAQ: You may use other federal funds to match ESG for– FAQ: You may use other federal funds to match ESG for the same activities, as long as that program allows it, and as long as you aren’t using ESG to match that program

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• HUD encourages use of match to support increased costs of planning and oversight

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Proposed Activities

• Recipient must provide details for each activity to be funded using second allocation of funds, as well as use of any reprogrammed funds (if applicable)

• Note that an “activity” is a program component + d t il F l “R id R h i H idetail. For example, “Rapid Re-housing – Housing Relocation and Stabilization Services” is one activityactivity

• There are 8 items that must be included – see Notice for detail

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Notice for detail• Details can be provided in any clear concise format

– See Notice for suggested formats32

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Proposed Activities

• Discussion of Funding Priorities– Explain recipient funding decisions (e.g. why did p p g ( g y

you choose to fund homelessness prevention over RRH?)o Highlight local objectives related to national

strategic prioritieso If locally-relevant data is available HUD stronglyo If locally relevant data is available, HUD strongly

encourages communities to use it to support priorities

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– Identify any obstacles to addressing underserved needs in the community.

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Detailed Budget

• Recipients must include detailed budget of planned activities and funding level

• Budget must account for entire second allocation and any reprogrammed funds from the first allocationallocation

• Recipients may use Table 3 to complete this requirementrequirement- Table assumes that recipients will obligate entire second

allocation and any reprogrammed funds to new activitiesIf i i t i i f d f h lt t h

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- If a recipient is proposing funds for shelter or outreach, and is eligible to do so, must contact local HUD field office for guidance

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Table 3: FY 2011 Detailed Budget Table

• Table 3 provides a format for describing detailed budgetdetailed budget

• Available as excel spreadsheet onspreadsheet on www.hudhre.info/esg

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Written Standards for Provision ofWritten Standards for Provision of ESG Assistance

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Written Standards

• Cities, Counties, and Territories: must describe written standards to be used indescribe written standards to be used in administering ESG activities

• States: must describe their written standards OR describe requirements for subrecipients to establish and implement written standards

• Recipients should continue to refine written standards as they complete Con Plans and A l A ti Pl th t f

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Annual Action Plans over the next few years

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Written Standards Required

Jurisdictions must establish a series of written standards as prescribed in the Interim Rule :a. Standard policies and procedures for evaluating persons or

families eligible for assistance;b Policies and procedures for coordination among providers;b. Policies and procedures for coordination among providers;c. Policies and procedures for determining and prioritizing who

will receive homeless prevention or rapid re-housing;d St d d f d t i i th ti i t h f t dd. Standards for determining the participant share of rent and

utilities;e. Standards for determining length and level of assistance; g g

andf. Standards for determining type, amount, and duration of

housing stabilization services including limits 38housing stabilization services including limits 38

Written Standards Required a. Standard policies and procedures for evaluating

individuals’ and families’ eligibility for assistance under Emergency Solutions Grant (ESG)Emergency Solutions Grant (ESG).

– Policies and procedures must be consistent with the definitions of homeless and at risk of homelessnessdefinitions of homeless and at risk of homelessness (24 CFR 576.2) as well as with record-keeping requirements

– Standards may be described generally

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Written Standards Required b. Policies and procedures for coordination among

emergency shelter providers, essential service providers, homelessness prevention and rapid re housinghomelessness prevention and rapid re-housing assistance providers, other homeless assistance providers, and mainstream service and housing providers.

− At recipient and subrecipient level, describe how ESG-funded activities will be coordinated with otherfunded activities will be coordinated with other homeless assistance and mainstream programs

− Section 576 400 (b) and (c) provide a list of theseSection 576.400 (b) and (c) provide a list of these programs

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Written Standards Required c. Policies and procedures for determining and prioritizing which eligible families and individuals will receive homelessness prevention assistance and which eligiblehomelessness prevention assistance and which eligible families and individuals will receive rapid re-housing assistance.

- How will jurisdiction prioritize individuals and families who are eligible?H li i / d i l d- How can policies/procedures include as many homeless families as possible for rapid re-housing, including those with multiple housing barriersg p g

- Ability to sustain housing should be a program goal, not a threshold requirement

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Written Standards Required d. Standards for determining what percentage, or amount, of rent and utilities costs each program participant must pay, if any while receiving homelessness prevention or rapid reany, while receiving homelessness prevention or rapid re-housing assistance.

- Consider local challenges associated withConsider local challenges associated with homelessness, other resources available or lacking, existing housing, and economic conditions in the communitycommunity

- Can be flexible and consider a wide range options for participant’s contribution to rent and utilitiesparticipant s contribution to rent and utilities.

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Written Standards Required e. Standards for determining how long a particular program participant will be provided with rental assistance and whether and how the amount of that assistance will bewhether and how the amount of that assistance will be adjusted over time.

- Must ensure regulatory provisions are not violated when developing standards (see notice and Interim Rule for more detail)

Consider local challenges associated with- Consider local challenges associated with homelessness, other resources available or lacking, existing housing and economic conditions in the community

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Written Standards Required f. Standards for determining the type, amount, and duration of housing stabilization and/or relocation services to provide a program participant, including the limits, if any, on theprogram participant, including the limits, if any, on the homelessness prevention or rapid re-housing assistance that each program participant may receive, such as the maximum amount of assistance maximum number of months the programamount of assistance, maximum number of months the program participant receives assistance, or the maximum number of times the program participant may receive assistance.

- No participant may receive more than 24 months of assistance within a 3-year period

Within that limit recipients have flexibility to consider a- Within that limit, recipients have flexibility to consider a wide range of options

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Process for Making Sub-Awards

Each recipient must describe its process for making sub-awards, including:g g

– Description of review and award process– How awards will be made available to non-How awards will be made available to non

profit organizations or local governments

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Homeless Participation Requirement

• Recipients (excluding states) must provide for the participation of homeless or formerly homeless individual on the Board of Directors or other equivalent policymaking entity of the recipient, ORIf bl t t th b i t th• If unable to meet the above requirement, the recipient must include in substantial amendment, the plan to consult with homeless or formerlythe plan to consult with homeless or formerly homeless individuals in considering and making policies and decisions regarding any ESG-funded

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facilities, services, or other assistance.

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Performance Standards• Recipient must describe performance standards to be

used in evaluating ESG activitiesStandards must be created in consultation with Continuum of– Standards must be created in consultation with Continuum of Care, per Interim Rule

– Standards go beyond performance indicators to provide a measure to evaluate subrecipient’s success at:measure to evaluate subrecipient s success at:

• Targeting those who need assistance most• Reducing number of people living on streets or in shelters

Sh t i ti t h l• Shortening time spent homeless• Ensuring assistance provided is effective at reducing housing

barriers and housing stability risksConsider performance measures detailed in Section 427 of the

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– Consider performance measures detailed in Section 427 of the McKinney-Vento Act, as amended by the HEARTH Act, and how ESG performance will complement or contribute to these.

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Certifications to be Submitted

• A new certification form will be provided by HUD, required for submission by all recipients.

• It includes:– Rehabilitation/Conversion of Facilities– Minor Renovations of Facilities– Duration of Services

Obt i i A i t– Obtaining Assistance– Matching Funding– Confidentiality of Records

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– Confidentiality of Records– Institutional Discharge

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Written Standards for Emergency Shelter and Street Outreach

• IF local government recipients and territories are proposing to and are eligible to use funds from 2nd

allocation for emergency shelter or street outreachallocation for emergency shelter or street outreach activities, they must establish and describe standards.

• Local governments and territories must describe:– Standards for targeting and providing any essential services

related to street outreach– Policies and procedures for admission, diversion, referral and o c es a d p ocedu es o ad ss o , d e s o , e e a a d

discharge by any emergency shelters, including standards for length of stay, safeguards for special populations, and serving individuals/families with highest barriers to housing.

– Policies and procedures for assessing, prioritizing, & re-assessing individual/family needs for essential services related to shelter

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Written Standards for Emergency Shelter and Street Outreach (cont’d)

• IF States are proposing to and are eligible to use funds from 2nd allocation for emergency shelter or street outreach activities they must establish and describeoutreach activities, they must establish and describe standards.

• States must either: 1) include own written standards as local governments

and territories must do for those activities (same as prior slide) orprior slide), or

2) describe requirements for its subrecipients to establish and implement the relevant written standards, as pprovided under 24 CFR 576.400(e)(2) and (3).

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Optional: “At risk of homelessness”

• Requirements for recipients who plan to use the risk factor under paragraph (1)(iii)(G) of the “atrisk factor under paragraph (1)(iii)(G) of the at risk of homelessness” definition:– If a recipient proposes to serve individuals or families at

risk of homelessness based on locally defined risk factor (24 CFR 576.2), the jurisdiction must include a description of the housing characteristics associated with instabilityof the housing characteristics associated with instability and increased risk of homelessness

• If a recipient does not provide this description, it cannot serve individuals and families using this criteria

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Requirements for Optional Changes toRequirements for Optional Changes to Annual Action Plan

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Centralized/Coordinated Assessment

• Recipients are not yet required to participate in a centralized or coordinatedparticipate in a centralized or coordinated assessment system

• However… if the community has established a centralized or coordinatedestablished a centralized or coordinated assessment system and the recipient or subrecipients use this system a description

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subrecipients use this system, a description should be provided

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Monitoring Activities

• Consolidated Plan requires a description of standards and procedures used for monitoringstandards and procedures used for monitoring activities to ensure long-term compliance with program requirementsp g q

• HUD encourages recipients to review, and d t i ti it iupdate as necessary, existing monitoring

standards and procedures (including staff resources) to assure compliance in

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resources) to assure compliance in implementing new program requirements

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Quiz: Substantial Amendment Budget Detail

1. The budget in the substantial amendment should only account for the planned uses of the 2nd

ll ti f f dallocation of funds.

True False

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Requirements that Apply to FY 2012 and Future Consolidated Planningand Future Consolidated Planning

Submission

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Future Consolidated Planning Submissions

• To receive FY 2012 funds and future fiscal years, ALL Consolidated Plan jurisdictions are required to comply with all the revised requirementsthe revised requirements– Specified in 24 CFR 91.100, 91.105, 91.220, and 91.225 for local

governments (and territories for ESG) and 24 CFR 91.110, 91 115 91 320 and 91 325 for States91.115, 91.320, and 91.325 for States

• After January 4, 2012 all submissions of Consolidated Plan jurisdictions’ housing and homeless needs assessments, h i k t l d t t i l ill b bj t thousing market analyses, and strategic plans will be subject to revised requirements that apply to submitting complete 5-year Consolidated Plan

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– If a jurisdiction recently submitted a Consolidated Plan BEFORE January 4, 2012, they will not be required to submit a revised Consolidated Plan

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Consolidated Annual Performance and Evaluation Report (CAPER)

• New ESG-specific reporting requirements (§91.520) apply to activities included in the substantial pp yamendment to the FY 2011 Annual Action Plan and future Annual Action Plans

• New homelessness reporting requirements (§91.520(c)) required of ALL Consolidated Plan jurisdictions (including those not receiving ESG funds) j ( g g )applies for FY 2012 and future program years

• HUD will issue further guidance about complying with

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these requirements

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Next Steps

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Building Capacity for the Long Run

• While the planning process for developing the FY 2011 substantial amendment is important2011 substantial amendment is important, recipients should approach it as only the first step in an ongoing comprehensive planning p g g p p gprocess.

• Principles and practices in the HEARTH Act will be applicable for years to come

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Planning the Substantial Amendment

• In all jurisdictions, substantive discussions ith C C t ti d thwith CoC representatives and other

organizations should be initiated as soon iblas possible

• Active consultation, coordination, and collaboration with key community systems and stakeholders is critical

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Consolidated Plan: Further Information

• HUD’s Homelessness Resource Exchange:h dh i fwww.hudhre.info

– The published ESG Interim Rule with Consolidated Plan changesPlan changes

– Consolidated Plan Regulation (highlighting changes from the ESG Interim Rule)

– Notice on application requirements FY 2011 ESG Second Allocation (forthcoming)Additi l id di th C lid t d Pl

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– Additional guidance regarding the Consolidated Plan Regulations (user guide, FAQ, etc) will be posted to www.hudhre.info in the near future.

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Additional Helpful Resources

• Resources on www.hudhre.info will eventually include all of the following: ―User Guides

―McKinney-Vento Act, as amended by the HEARTH Act

―All published program regulations

―Webinar recordings (available soon)

―At-a-glance charts and sample formsg p

―ESG Help Desk (now available)

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Webinar Evaluation

• You should now be able to:U d t d i t f i i th d– Understand requirements for receiving the second allocation of FY 2011 ESG funds

– Describe key requirements associated with spendingDescribe key requirements associated with spending the second allocation of funds

– Describe how to calculate the expenditure limit for h lt d t t t h ti itiemergency shelter and street outreach activities

• Please complete the on-line survey to rate how well this webinar met its objectiveswell this webinar met its objectives

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A t Q i Q tiAnswers to Quiz Questions

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Answers and Explanations for Quiz

• Quiz 1: TRUEThe total amount of fiscal year grant expended on street outreach andThe total amount of fiscal year grant expended on street outreach and

emergency shelter cannot exceed the greater of:• 60 percent of current fiscal year grant OR• Amount of FY 2010 grant funds spent on homeless• Amount of FY 2010 grant funds spent on homeless

assistance activities• Quiz 2:

FALSEFALSEIt is false because you need to make sure that if you re-program any funds, you also include the planned uses of these funds in the budget. So it’s not ONLY the 2nd allocation it’s the 2nd allocation plus anySo it s not ONLY the 2nd allocation – it s the 2nd allocation plus any reprogrammed funds. It is important to document how each dollar will be used differently for the NEW ESG activities.

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