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Presentation, discussion, and possible action on Program Year 2024 Emergency Solutions Grants Program Awards.
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RECOMMENDED ACTION
recommendation
WHEREAS, the Department received an allocation of $9,723,237 in Emergency Solutions Grants Program (ESG) funds for Fiscal Year 2024 from the U.S. Department of Housing and Urban Development (HUD) of which $9,285,692 was made available in accordance with 10 TAC Chapter 7, Subchapter C, Section 7.33, Apportionment of ESG Funds;
WHEREAS, the Board authorized release of the Notice of Funding Availability (NOFA) for the ESG Program totaling $9,285,692 on May 9, 2024;
WHEREAS, HUD regulations require the Department to award ESG funds within 60 days of HUD’s execution of the grant agreement, which was dated September 6, 2024;
WHEREAS, the Department evaluated organizations eligible for receipt of a Continuing Award in accordance with 10 TAC §7.34,Continuing Awards, and accepted Applications from 28 eligible Applicants and made offers of Continuing Awards to 27 Applicants totaling $5,511,795;
WHEREAS, the Department received 87 Applications from eligible Applicants under a Competitive Application cycle in response to the NOFA, with requests totaling $9,687,938;
WHEREAS, the Applications received under the NOFA have been reviewed and ranked in accordance with the requirements of 10 TAC §7.38(b); and
WHEREAS, the Previous Participation Review and Approval Process (PPRAP) has reviewed the compliance history of all Applicants, and recommends approval with conditions for San Antonio Metropolitan Ministry, Inc. (SAMM), Comal County Family Violence Shelter (CCFVS), and The Bridge Over Troubled Waters, Inc., and approval with no conditions for all other Applicants;
NOW, therefore, it is hereby
RESOLVED, that the Executive Director, his designees, and each of them be and they hereby are authorized, empowered, and directed, for and on behalf of the Department, to take any and all such actions as they or any of them may deem necessary or advisable to effectuate awards totaling $9,285,692 for ESG funding recommended under the ESG NOFA as detailed in Attachment B, as recommended by PPRAP.
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BACKGROUND
The ESG Program is a HUD-funded program designed to assist people experiencing homelessness or at-risk of homelessness to regain stability in permanent housing quickly after experiencing a housing crisis and/or homelessness. The program components under ESG include street outreach, emergency shelter, rapid re-housing, homelessness prevention, Homeless Management Information System (HMIS), and administration. Rapid re-housing and homelessness prevention may be used for housing relocation and stabilization services and short-term and medium-term rental assistance.
On May 9, 2024, the Board approved the release of a NOFA notifying prospective Applicants of availability of PY2024 ESG funds; the NOFA closed on June 24, 2024. The NOFA resulted in 27 offers for a Continuing Award and 33 Award offers under the Competitive Application cycle. The distribution of the Regional allocation between the Continuing Awards and the Competitive Cycle is summarized in Attachment C.
Applicants were assigned a random number as a tiebreaker for use in case of a tied score, per 10 TAC §7.38(d). Applicants were ranked by score and then by tiebreaker number, with the high numbers ranking higher than lower numbers. Recommendation of a Continuing Award is not determined by a score, therefore these Applications will not note scores or a tie breaker number. The final scores were determined after a staff review, which when necessary and requested by staff allowed the opportunity for Applicants to provide clarification, correction, or non-material missing information. This information was requested to resolve inconsistencies in the original Application or to assist staff in evaluating the Application, per 10 TAC §7.37(b).
After completion of the scoring and ranking process, award recommendations were determined in accordance with the process outlined in 10 TAC §7.38 through two levels of funding. Level one of funding is for the highest ranked Applicants within each CoC region, until the funding is exhausted or until there is an offer of a partial award. Level two pools unused funds from level one of funding and offers the pooled funds to the highest ranked Applications statewide.
The Department received two appeals in response to application scoring, which did not result in a change to funding recommendations. BEAT AIDS and Sarah’s House appealed staff’s determination of point reduction as a result of inaccurate reporting of match and outcomes as required by 10 TAC §7.5. Although the appeals were denied, both applications are recommended for the full requested funds, as they were still eligible under the regional award.
The total amounts available by CoC region, and the total requests received are listed in Attachment A. The requirements set forth in 24 Code of Federal Regulations (CFR) §576.100(b)(1) mandates that no more than 60% of the state’s ESG allocation be used for street outreach and emergency shelter. As a result, in some cases, higher scoring Applicants with emergency shelter or street outreach Applications were offered a partial award to ensure that the state would not exceed this cap. The Emergency Shelter and Street Outreach Cap per Region is summarized in Attachment C.
All Applications recommended for award through the NOFA and direct award recommendation have been reviewed for previous participation. On September 30, 2024, PPRAP recommended an approval with conditions for San Antonio Metropolitan Ministries, Inc. (SAMM), Comal County Family Violence Shelter (CCFVS), and The Bridge Over Troubled Waters, Inc. (TBOTW). Their awards are conditioned upon the following: Applicant is required to provide all documentation relating to the FYE 2023 Single Audit on or before December 1, 2024. The compliant Single Audit must also be uploaded to the Federal Audit Clearinghouse (FAC), with confirmation provided to the Department. Depending on the results of that Single Audit, the Department may impose additional conditions upon the Contract in accordance with 2 CFR §200.207. In addition to the condition recommended by PPRAP, TBOTW is currently within their corrective action period for the Department’s review of the FY 2022 Single Audit. As the deadline (October 18, 2024) for the corrective action response is prior to the ESG Contract start date, if it results in disallowed costs, in accordance to 10 TAC 1.21(d) the Department will not enter into a Contract with TBOTW unless there is a satisfactorily resolution on or before December 1, 2024. If any Applicant does not meet the requirements of their condition, the funds allocated to their respective organizations will be reallocated. PPRAP recommended approval with no conditions for all other Applicants.
The results of the NOFA, including funding recommendations, are included for approval as Attachment B for the Regional competition and Attachment D for the Statewide Competition.