Pandemic Darlings The pandemic economy, in original documents
Home Source documents Emergency Solutions Grants CARES Act Program — Office of Community Planning and Development, 2022-LA-0002

Emergency Solutions Grants CARES Act Program — Office of Community Planning and Development, 2022-LA-0002

Summary

HUD Office of Inspector General audit report 2022-LA-0002, dated August 17, 2022, addressed to Marion McFadden from Kilah S. White, Assistant Inspector General for Audit, on challenges in implementing the Emergency Solutions Grants CARES Act (ESG-CV) program. The OIG used a survey questionnaire of the 362 grant recipients and reports that, when the audit began in July 2021, recipients had spent $563,178,336 of $3.96 billion. It says recipients needed an extension beyond the September 30, 2022 spending deadline, which HUD later extended, and that staff capacity and coordinating with other pandemic funding were top challenges. It recommends that the Office of Community Planning and Development consider recipients' challenges in its risk assessments.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Cite this document

“Emergency Solutions Grants CARES Act Program — Office of Community Planning and Development, 2022-LA-0002.” Original at www.hudoig.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/hud-oig-2022-la-0002-3f155c5bf5/, SHA-256 ebb1807f2ce345a4169f3bd2ccaa321bb87b2e6fbe6ce59fa0129748f7014f67.

Full text

Emergency Solutions Grants
CARES Act Program
Office of Community Planning and Development,
Washington, DC | 2022-LA-0002


August 17, 2022




Office of Audit | Office of Inspector General
U.S. Department of Housing and Urban Development
Date:    August 17, 2022

To:      Marion McFadden
         Principal Deputy Assistant Secretary for Community Planning and Development, D

         //signed//
From: Kilah S. White
      Assistant Inspector General for Audit, GA

Subject: Emergency Solutions Grants CARES Act Implementation Challenges

Attached are the U.S. Department of Housing and Urban Development (HUD), Office of Inspector
General’s (OIG) final results of our audit of HUD’s Emergency Solutions Grants Coronavirus Aid, Relief, and
Economic Security Act (CARES Act) program.

HUD Handbook 2000.06, REV-4, sets specific timeframes for management decisions on recommended
corrective actions. For each recommendation without a management decision, please respond and
provide status reports in accordance with the HUD Handbook. Please furnish us copies of any
correspondence or directives issued because of the audit.

The Inspector General Act, Title 5 United States Code, appendix 8M, requires that OIG post its reports on
the OIG website. Accordingly, this report will be posted at https://www.hudoig.gov.

If you have any questions or comments about this report, please do not hesitate to call Tanya Schulze,
Audit Director, at (213) 534-2471.




Office of Inspector General | U.S. Department of Housing and Urban Development                      Page | 2
451 7th Street SW, Washington, DC 20410 | P: 202-708-0430 | F: 202-401-2505 | www.hudoig.gov
Highlights
EMERGENCY SOLUTIONS GRANTS CARES ACT IMPLEMENTATION
CHALLENGES | 2022-LA-0002

What We Audited and Why
We audited the U.S. Department of Housing and Urban Development’s (HUD) Emergency Solutions
Grants Coronavirus Aid, Relief, and Economic Security Act (CARES Act) (ESG-CV) program.

Our audit objective was to determine what challenges ESG-CV grant recipients faced in implementing the
program and using grant funds. We used a survey questionnaire to gather feedback and insight directly
from the 362 recipients of ESG-CV grants.

At the time we initiated this audit in July 2021, ESG-CV grant recipients had spent $563,178,336 of
available $3.96 billion grant funds. We performed this audit to assist HUD’s Office of Community
Planning and Development in identifying opportunities to improve the timeliness and use of ESG-CV grant
funds.

What We Found
Our survey questionnaire of the ESG-CV grant recipients found that they faced challenges in
implementing the program and using grant funds. The grant recipients needed an extension beyond the
spending deadline of September 30, 2022, to use a majority or all of their ESG-CV funds. HUD
subsequently extended the spending deadline to help address this issue. The top challenges identified by
the grant recipients included staff capacity and coordinating with other sources of pandemic related
funding. In addition, a majority of the grant recipients that provided ESG-CV funds to subrecipients stated
that the pandemic impacted their ability to effectively monitor their ESG-CV subrecipients. As a result,
while HUD has taken action to help address the spending deadline concerns, the grantees’ challenges
with capacity, multiple funding sources, and monitoring their subgrantees may increase the risk of misuse
of the funds. HUD can use the results of our survey questionnaire to potentially improve the continued
implementation of the ESG-CV program and to inform its risk assessment of ESG-CV grantees.

What We Recommend
We recommend that the Principal Deputy Assistant Secretary for Community Planning and Development
consider including grant recipients’ challenges with capacity, multiple sources of funding, and subgrantee
monitoring as part of CPD’s risk assessments.




Office of Inspector General | U.S. Department of Housing and Urban Development                      Page | 3
451 7th Street SW, Washington, DC 20410 | P: 202-708-0430 | F: 202-401-2505 | www.hudoig.gov
Table of Contents
Background and Objective ........................................................................................ 5
Results of Audit ............................................................................................................. 7
   Finding: ESG-CV Grant Recipients Faced Challenges in Implementing the Program and Using Grant
   Funds.......................................................................................................................................................7

Scope and Methodology ........................................................................................... 12
Appendixes ................................................................................................................... 13
   Appendix A - Auditee Comments and OIG’s Evaluation ...................................................................... 13
   Appendix B - Survey Questionnaire Results ........................................................................................ 14
Background and Objective
Congress provided $4 billion 1 in the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) for
the Emergency Solutions Grants (ESG) program with two rounds of funding, referred to as “ESG-CV”
grants, as follows:

     1. Round 1. $1 billion allocated under the annual ESG formula to grant recipients.

     2. Round 2. $2.96 billion allocated under a formula “for the benefit of unsheltered homeless,
        sheltered homeless, and those at risk of homelessness, to geographical areas with the greatest
        need based on factors to be determined by the [HUD] Secretary, such as risk of transmission of
        coronavirus, high numbers or rates of sheltered and unsheltered homeless, and economic and
        housing market conditions as determined by the Secretary.”

As of April 1, 2022, ESG-CV recipients had drawn nearly $1.65 billion, or 42 percent, of the $3.96 billion
ESG-CV amount. Please refer to the table below.


     ESG CARES              Total allocated 2            Obligated 3 in            Funded 5          Drawn 6
      funding                   by HUD                       IDIS 4                activities        amount

    $3,960,000,000           $3,960,000,000             $3,960,000,000           $3,683,016,994   $1,651,352,820



The CARES Act required that ESG-CV funds be used to prevent, prepare for, and respond to coronavirus
among individuals and families who are homeless or receiving homeless assistance and to support
additional homeless assistance and homelessness prevention activities to mitigate the impacts created by
coronavirus. The CARES Act also authorized HUD to waive, or specify alternative requirements for, any
provision of any statute or regulation that the Secretary administers in connection with the obligation by
the Secretary or the use by the recipients of these amounts, except for requirements related to fair
housing, nondiscrimination, labor standards, and the environment. The CARES Act also established that
ESG-CV funds remain available until September 30, 2022. The ESG-CV funding represented a 1,379
percent increase to the regular 2020 annual ESG appropriation. To ensure that ESG-CV funds are spent
quickly on eligible activities to address the public health and economic crises caused by coronavirus, HUD




1
    HUD committed $40 million of the appropriated funds to technical assistance to recipients of ESG-CV to build
    capacity and facilitate speedy implementation.
2
    HUD awarded $3.96 billion in funds to 362 grant recipients.
3
    HUD signed grant agreements and made funds available for disbursement.
4
    The Integrated Disbursement and Information System (IDIS) provides HUD with current information regarding
    the program activities underway across the Nation, including funding data. HUD uses this information to report
    to Congress and to monitor grant recipients.
5
    Grant recipients must fund a grant activity in IDIS before funds may be drawn.
6
    Grant recipients have drawn funds to pay for grant-specific activities.

Emergency Solutions Grants CARES Act Program                                                                Page | 5
Office of Inspector General | U.S. Department of Housing and Urban Development
published Office of Community Planning and Development (CPD) Notice CPD-20-08 and established
progressive expenditure deadlines and recapture provisions as follows:

     1. HUD may recapture up to 20 percent of a recipient’s total award, including first and second
        allocation amounts, if the recipient has not spent at least 20 percent of that award by September
        30, 2021.

     2. HUD may recapture up to 80 percent of a recipient’s total award, including first and second
        allocation amounts, if the recipient has not spent at least 80 percent of that award by March 31,
        2022.

     3. Before recapturing funds as described above, HUD will follow the enforcement process in 24 CFR
        (Code of Federal Regulations) 576.501 and provide the recipient with an opportunity to provide a
        spending plan demonstrating to HUD’s satisfaction that all of the recipient’s ESG-CV funds from
        the first and second allocations will be spent by September 30, 2022.

The ESG-CV funding provided through the CARES Act is expected to mitigate the health and economic
impact of COVID-19 among some of the Nation’s most vulnerable individuals and families. These funds
will help communities implement infection control protocols to limit the spread of the virus among
people experiencing homelessness, especially those in unsheltered and congregate shelter settings. The
funds will also provide resources to housing programs that will most certainly see an increase in requests
for assistance because of the economic downturn created by the pandemic response.

Eligible ESG recipients generally consist of States, metropolitan cities, urban counties, and territories, as
defined in 24 CFR 576.2. ESG subrecipients may include units of general-purpose local government or
private nonprofit organizations. Local governments (whether recipients or subrecipients) may also
subgrant ESG funds to public housing agencies and local redevelopment authorities. HUD encourages
eligible subrecipients to contact their local government for information about applying for ESG-CV
funding.

Our audit objective was to determine what challenges ESG-CV grant recipients faced in implementing the
program and using grant funds.




Emergency Solutions Grants CARES Act Program                                                            Page | 6
Office of Inspector General | U.S. Department of Housing and Urban Development
Results of Audit
FINDING: ESG-CV GRANT RECIPIENTS FACED CHALLENGES IN
IMPLEMENTING THE PROGRAM AND USING GRANT FUNDS
ESG-CV grant recipients faced challenges in implementing the program and using grant funds. The survey
questionnaire results 7 found that 39 percent of the grant recipients that responded may need an
extension beyond the spending deadline of September 30, 2022, to use a majority or all of their ESG-CV
funds. 8 The top two challenges experienced by the grant recipients as a result of the pandemic were staff
capacity and coordinating with other sources of funds. Further, the majority of the grant recipients that
provided ESG-CV funds to subrecipients stated that the pandemic impacted their ability to effectively
monitor their ESG-CV subrecipients. We attribute that these conditions occurred because grant recipients
were awarded large amounts of ESG-CV funding with the expectation it would be implemented and used
quickly to address the needs of the homeless during an unprecedented pandemic. As a result, grantee
recipients’ challenges in (1) capacity, (2) multiple funding sources, and (3) monitoring their subgrantees
may increase the risk of misuse of the funds.



Grant Recipients’ Ability to Meet the ESG-CV Spending Deadline
Most grant recipients 9 stated that they expect to use a majority or all of their ESG-CV funds by the
spending deadline of September 30, 2022; however, 39 percent stated that an extension may be needed.
Please refer to the table below for additional responses regarding the ability to spend by the spending
deadline.




7
    Eighty-six percent of the grant recipients responded to the survey questionnaire. Refer to Scope and
    Methodology section for survey questionnaire methodology and response rate information.
8
    Subsequent to our survey questionnaire, on April 18, 2022, HUD extended the spending deadline to September
    30, 2023.
9
    Of the 362 ESG-CV grant recipients, 313 responded, and 49 did not. The survey questionnaire allowed the 313
    respondents to check all that applied to them in regard to the spending deadline of September 30, 2022. As a
    result, there were 402 responses (See appendix B, question 16).

Emergency Solutions Grants CARES Act Program                                                              Page | 7
Office of Inspector General | U.S. Department of Housing and Urban Development
                                               Spending Deadline
                                              September 30, 2022
 180                                                                                                                          45%
 160                                                                 39%                                                      40%
 140                                                                                                                          35%
 120                                          29%                                                                             30%
                                                               156
 100                   24%                                                                                                    25%
  80                                    115                                                                                   20%
                  96
  60                                                                                                                          15%
  40                                                                                                                          10%
                                                                                            8%               4
  20                                                                                   31                                     5%
                                                                                                                 1%
   0                                                                                                                          0%
        Yes, all funding will be Yes, a majority of the Yes, but extensions      No, signficant        No, significant
                  used            funds will be used      may be needed        amounts will remain amounts will remain
                                                                              unused due to various unused due to lack of
                                                                                   challenges               need


More than half of the respondents, 56 percent, found it challenging spending their agency’s allocated
ESG-CV funds to prevent, prepare for, and respond to coronavirus compared to spending their regular
annual ESG grant funds. (See appendix B, question 4.) In addition, 47 percent believed it was difficult to
implement the ESG-CV program in comparison to the regular annual ESG program. (See appendix B,
question 3.)

As of April 1, 2022, two years after the first tranche of grant funds were awarded, the grant recipients had
drawn $1.65 billion, 10 or 42 percent, of the $3.96 billion in ESG-CV funds. Therefore, grant recipient
concerns that they may not be able to fully spend the remaining $2.31 billion by the September 30, 2022,
spending deadline appear to be warranted.

Subsequent to our questionnaire survey, on April 18, 2022, HUD issued Notice: CPD-22-06, Waivers and
Alternative Requirements for the Emergency Solutions Grants Program Under the CARES Act (ESG-CV);
Amendments and Clarifications. The Notice extended the overall deadline for expending ESG-CV funds. It
stated that the recipients must expend all amounts through the first and second allocations of ESG-CV
funds by September 30, 2023, except for administration and HMIS funds necessary for ESG-CV closeout,
which must be expended by December 31, 2023. HUD determined that the new expenditure deadline
was necessary because the pandemic lasted much longer than initially anticipated and “continues to
cause significant risk to the public health and safety of the Nation.” HUD determined that ESG-CV
activities will still be needed to prevent, prepare for, and respond to coronavirus after the original grant
date of September 30, 2022. We believe the extension to the deadline will help alleviate the grant
recipients concerns regarding spending 11 and ensure funds will continue to be made available to address
pandemic related needs of the homeless.




10
     Specifically, $1,651,352,820 drawn to pay for grant-specific activities, as of April 1, 2022.
11
     HUD extended the spending deadline after the survey questionnaire addressing the grantee recipients’
     concerns; therefore, we have not included a recommendation on extensions.

Emergency Solutions Grants CARES Act Program                                                                                Page | 8
Office of Inspector General | U.S. Department of Housing and Urban Development
Top ESG-CV Challenges Identified by Grant Recipients
Nearly half of the grant recipients, 49 percent, experienced challenges as a result of the COVID-19
pandemic that prevented their agency from meeting the goals of the ESG-CV program; specifically, to
prevent, prepare for, and respond to coronavirus to help individuals and families who are homeless. (See
appendix B, question 5.) According to the survey questionnaire results, staff capacity and challenges
coordinating with other sources of funds were among the top two challenges that prevented their
agencies from meeting the ESG-CV objective. 12 (See appendix B, question 6.) Please refer to the
Challenges table 13 below for the number of grant recipient responses to each of the challenges.


                                                                                         Challenges
 140                                                                                                                                                                                                              30%
 120                                                                                                                                                                                                              25%
                                                                                                             24%
 100                                                                                          119
                                                                                                                                                                                                                  20%
     80
                                                                                   14%                                               14%                         15%                                              15%
     60                                                                  69                                                   71                          73
                                                          10%                                                                                                                                             10%     10%
     40                          9%              52                                                                                                                                               52
                   45
     20                                                                                                                                                                                                           5%
                                                                                                                                                                              17 3%
     0                                                                                                                                                                                                            0%

                                                                                                                    Planning challenges (for     Challenges coordinating


                                                                                                                                                                            Travel restrictions
                                                                                           Capacity needs (for
                                        Systems-technology issues   Project delays and
            Fear of possible COVID-19
                                                                                                                                                                                                  Other

                                                                                                                     example, action plan,        with other sources of
                                           and communication         additional costs

                                                                                         example, staff shortage)
                                                                                                                    activity setup, reporting

              and case resurgance
                                                                                                                                                funds (for example, CDBG,

                                                problems
                                                                                                                         requirements)
                                                                                                                                                         HOPWA)


Forty two percent stated that they anticipated future challenges in administering the ESG-CV program.
(See appendix B, question 10.) The grant recipients that anticipated future challenges specified that
continued staff capacity was the highest anticipated challenge at 24 percent. (See appendix B, question
11).

Most grant recipients, 63 percent, stated they received other source(s) of non-HUD funding, such as
Federal Emergency Management Agency, state, and local sources, to address homelessness. As detailed
in the Impact of non-HUD funding table, 14 64 percent, 15 of these grant recipients stated that the non-
HUD funds have either moderately or significantly impacted their ESG-CV funds. (See appendix B,


12
   We did not validate the grant recipients’ concerns, as it was outside the scope of the audit. (See Scope and
   Methodology.)
13
   As noted in the table, CDBG is the Community Development Block Grant program and HOPWA is the Housing
   Opportunities for Persons with AIDS program. There was also a 1 percent difference in the table’s combined
   total percentage due to rounding.
14
   There was a 1 percent difference in the table’s combined total percentage due to rounding.
15
   We combined the 68 respondents, 35 percent, and 57 grant recipients, 29 percent, that stated moderate or
   significant impediment.

Emergency Solutions Grants CARES Act Program                                                                                                                                                                    Page | 9
Office of Inspector General | U.S. Department of Housing and Urban Development
questions 12 and 13.) As noted in the chart above, the grant recipients as a whole identified coordinating
with other sources of funds as the second highest challenges (15 percent). (See appendix B, question 11).


                                       Impact of non-HUD funding

      No effect            39 grant recipients (20%)

     Significant                                                  57 grant recipients (29%)

     Moderate                                                                     68 grant recipients (35%)

         Minor                         33 grant recipients (17%)

                   0        10              20            30             40            50             60            70         80


Subrecipient Monitoring
The majority of grant recipients, 87 percent, stated they provided ESG-CV funds to subrecipients to
administer. (See appendix B, questions 14 and 15.) As detailed in the chart below, 84 percent 16 of those
grant recipients stated that the pandemic impacted their ability to effectively monitor subrecipients, and
ultimately the program. 17


                            Impact on monitoring subrecipients

     No effect           45 grant recipients (16%)


 Significant                           57 grant recipients (21%)


     Moderate                                                                                  114 grant recipients (42%)


         Minor                        57 grant recipients (21%)


                   0             20                  40                  60                   80              100             120




16
       We combined the top three categories 1) 114 respondents, 42 percent, that stated moderate; 2) 57 grant
       recipients, 21 percent, that stated significant; and 3) 57 grant recipients, 21 percent that stated minor impact on
       monitoring subrecipients.
17
       We did not verify funds provided to subrecipients or the pandemic’s impact on monitoring as it was outside the
       scope of this audit. (See Scope and Methodology.)

Emergency Solutions Grants CARES Act Program                                                                                Page | 10
Office of Inspector General | U.S. Department of Housing and Urban Development
HUD stated that it did not collect subrecipient contact information and subgrantee information would not
necessarily be entered by the grant recipients into HUD’s IDIS data system 18. In addition, HUD relies on
the grant recipients to monitor their own subrecipients; therefore, the risk to the program increases if the
ESG-CV grant recipients ability to effectively monitor their subrecipients has been impacted by the
pandemic.

Conclusion
Many grant recipients have faced difficulty in spending a majority or all of their ESG-CV funds and needed
an extension beyond the spending deadline of September 30, 2022. Subsequent to our survey
questionnaire, HUD extended the spending deadline to September 30, 2023, which we believe will help
alleviate the grant recipients concerns and allow the funding to remain available to address the pandemic
related needs of the homeless. The top two challenges experienced by grant recipients due to the
pandemic were staff capacity (24 percent) and coordinating with other sources of funds (15 percent). In
addition, a majority of grant recipients that provided ESG-CV funds to subrecipients stated that the
pandemic impacted their ability to effectively monitor their ESG-CV subrecipients. We attribute that
these conditions occurred because grant recipients were awarded large amounts of ESG-CV funding with
the expectation it would be implemented and used quickly to address the needs of the homeless during
an unprecedented pandemic. As a result, the grant recipients’ challenges with capacity, multiple funding
sources, and monitoring may increase the risk of misuse of the funds.

Recommendations
We recommend that the Principal Deputy Assistant Secretary for Community Planning and Development

          1A. Consider grant recipients’ feedback on challenges with (1) capacity, (2) multiple other sources
              of funding, and (3) subrecipient monitoring as part of CPD’s risk assessments.




18
     HUD’s IDIS data system had information on ESG-CV subrecipient commitment and draw activity. However, there
     was no subrecipient contact or performance related information. We did not verify the accuracy or
     completeness of the subrecipient information as it was not within the audit’s scope and objective.

Emergency Solutions Grants CARES Act Program                                                           Page | 11
Office of Inspector General | U.S. Department of Housing and Urban Development
Scope and Methodology
We conducted the audit remotely from July 23 through October 18, 2021. Our audit covered the period
March 27, 2020, to July 31, 2021. To accomplish our audit, we developed a questionnaire and sent it to
all participating ESG-CV grant recipients.

The audit universe consisted of 362 grant recipients that received a combined total of $3.96 billion for the
first and second allocation of ESG-CV funds. We used Microsoft Forms to create the questionnaire for
ESG-CV grant recipients to complete. HUD headquarters provided the contact information 19 generated
from Sage 20. We sent an email with a hyperlink for the ESG-CV recipients to access to our questionnaire
online. During the 3-week response period, 21 we received 313 responses from the 362 ESG-CV grant
recipients contacted, or an 86 percent (313 divided by 362) response rate. We included the survey
questionnaire results 22 in appendix B for additional reference.

ESG-CV designated points of contact answered questions in the two categories: (1) the ESG-CV program
focusing on general questions related to the implementation of the program and (2) ESG-CV program
challenges and experiences. These questions were closed ended, and the questionnaire generally used a
descriptive rating scale for tracking and evaluation purposes and optional comment boxes. We
determined that a 100 percent selection method was appropriate since the online survey questionnaire is
an effective and efficient method of data collection. Specifically, we relied on the information obtained
through Microsoft Forms to collect responses from the designated points of contact. As a result, we
determined that the information from the program was sufficient to meet the objective of our audit.

We conducted the audit in accordance with generally accepted government auditing standards. Those
standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to
provide a reasonable basis for our findings and conclusions based on our objective(s). We believe that
the evidence obtained provides a reasonable basis for our conclusions based on our objective.




19
     In instances such as when emails were undeliverable, we obtained alternate email addresses from field office
     directors and CPD staff emails or the IDIS PR 32 Grantee Contact Information Report.
20
     The Sage Homeless Management Information System (HMIS) Reporting Repository is a web-based reporting
     portal that allows ESG homeless assistance grant recipients to submit their ESG-Consolidated Annual
     Performance and Evaluation Report and ESG-CV Quarterly reports to HUD.
21
     We extended the survey questionnaire deadline an additional week, to October 5, 2021, to help meet the
     minimum 80 percent submission rate for the survey questionnaire.
22
     In addition to the results documented in appendix B, respondents had the opportunity to submit optional
     written comments as part of the survey questionnaire. Examples of the comments have been included in the
     applicable sections of the finding.

Emergency Solutions Grants CARES Act Program                                                                Page | 12
Office of Inspector General | U.S. Department of Housing and Urban Development
Appendixes
APPENDIX A - AUDITEE COMMENTS AND OIG’S EVALUATION

CPD chose not to provide comments for inclusion in the final report.




Emergency Solutions Grants CARES Act Program                                     Page | 13
Office of Inspector General | U.S. Department of Housing and Urban Development
APPENDIX B - SURVEY QUESTIONNAIRE RESULTS

                        Questions and selection choices                                       Total               Percentage

 1. How would you rate how easy it was for your agency to find
 or be made aware when HUD issued its ESG-CV program notices
 guidance and waivers? For example: A notice was published on
 April 14, 2021: Notice CPD-21-05: Waiver and Alternative
 Requirements for the Emergency Solutions Grants (ESG)
 Program Under the CARES Act.
                                                                                 Easy          201                  64%
                                                                           Neutral              99                  32%
                                                                           Difficult            12                   4%
                           Not aware of the program notices and waivers                          1                  0% 23
                                                                             Total             313                  100%


                          Ease of locating HUD-issued
                  ESG-CV program notices, guidance, and waivers
                                                                                            Not aware - 1 grant
                    Difficult - 12 grant
                                                                                             recipient (0.3%)
                     recipients (4%)



                        Neutral - 99 grant
                         recipients (32%)

                                                                                        Easy - 201 grant
                                                                                        recipients (64%)




 2. How would you rate the ease in understanding program
 notices and waivers issued in response to the COVID-19
 pandemic to help your agency meet the ESG-CV program’s goals
 and objective?
                                                                                 Easy          101                  32%
                                                                           Neutral             155                  50%

23
     Rounded down because number was less than a full percent. Specifically, it was 0.3 percent.

Emergency Solutions Grants CARES Act Program                                                                           Page | 14
Office of Inspector General | U.S. Department of Housing and Urban Development
                        Questions and selection choices                                         Total       Percentage

                                                                           Difficult             56           18%
                                                                                 Total         312 24         100%


                        Ease in understanding HUD-issued
                  ESG-CV program notices, guidance, and waivers

                   Difficult - 56 grant
                    recipients (18%)                                                     Easy - 101 grant
                                                                                         recipients (32%)




                           Neutral - 155 grant
                            recipients (50%)




 3. How would you rate the ease of implementing the ESG-CV
 program compared to your agency’s regular annual ESG
 program?

                                                                                 Easy            53           17%
                                                                           Neutral              113           36%
                                                                           Difficult            147           47%
                                                                                 Total          313           100%




24
     A grant recipient indicated that it was not aware of the program notices and waivers. Therefore, the survey
     questionnaire did not branch out to this sub question for that particular respondent. As a result, there were only
     312 respondents for this question.

Emergency Solutions Grants CARES Act Program                                                                     Page | 15
Office of Inspector General | U.S. Department of Housing and Urban Development
                        Questions and selection choices                                         Total              Percentage


                     Ease in implementing the ESG-CV program

                                                                                          Easy - 53 grant
                                                                                         recipients (17%)




              Difficult - 147 grant
               recipients (47%)

                                                                                         Neutral- 113 grant
                                                                                          recipients (36%)




 4. How would you rate the challenge of spending your agency’s
 allocated ESG-CV funds to prevent, prepare for, and respond to
 coronavirus, compared to spending your regular annual ESG
 grant funds?
                                                                                 Easy            27                   9%
                                                                           Neutral               110                 35%
                                                                           Difficult             176                 56%
                                                                                 Total           313                 100%


                                      Challenge of spending allocated
                                              ESG-CV funds
                                                                                            Easy - 27 grant
                                                                                            recipients (9%)




                 Difficult - 176 grant
                  recipients (56%)

                                                                                             Neutral - 110 grant
                                                                                              recipients (35%)




Emergency Solutions Grants CARES Act Program                                                                            Page | 16
Office of Inspector General | U.S. Department of Housing and Urban Development
                        Questions and selection choices                                     Total           Percentage

 5. Has your agency experienced challenges as a result of the
 COVID-19 pandemic that have not allowed your agency to meet
 the goals of ESG-CV funds; specifically, to prevent, prepare for,
 and respond to coronavirus to help individuals and families who
 are homeless?
                                                                                  Yes        153              49%
                                                                                   No        160              51%
                                                                                 Total       313              100%


                                      Challenges as a result of the
                                         COVID-19 pandemic
                                                                                          Yes - 153 grant
                                                                                         recipients (49%)




                       No - 160 grant
                      recipients (51%)




 6. If Yes, what are the specific challenges that are not allowing
 your agency to prevent, prepare for, and respond to coronavirus
 to help individuals and families who are homeless. Check all
 that apply.

                          Fear of possible COVID-19 and case resurgence                      45                9%
             Systems-technology issues and communication problems                            52               10%
                                         Project delays and additional costs                 69               14%
                                         Capacity needs (e.g. staff shortage)                119              24%
        Planning challenges (e.g. action plan, activity setup, reporting                     71               14%
                                                          requirements)
     Challenges coordinating with other sources of funds (e.g. CDBG,                         73               15%
                                                            HOPWA)


Emergency Solutions Grants CARES Act Program                                                                     Page | 17
Office of Inspector General | U.S. Department of Housing and Urban Development
                        Questions and selection choices                                  Total     Percentage

                                                              Travel restrictions         17           3%
  Other 25: 1) Eviction moratorium/rent moratorium, 2) Shortage of                        52          10%
  housing, 3) Spending threshold deadlines, 4) IDIS and HMIS issues
   5) Processing internal approvals, executing agreements and State
    Board of Accounts 6) Amount of funding sources of available, 7)
     Not having enough service providers with the capacity to utilize
 the funds, 8) Potential duplication of services and identifying more
     subrecipients willing to participate in the program, 9) COVID-19
  infections in staff, 10) Inability to shelter individuals in congregate
 settings during the coldest months to avoid spreading coronavirus,
          11) Lengthy environmental reviews, 12) Limited affordable
     housing inventory/resources, 13) Staff turnover and quarantine
            throughout the last fiscal year that’s caused delays in our
      processes, 14) Issues related to land use issues in developing a
    shelter, 15) Increased bureaucracy, 16) Jurisdiction coordinating
      challenges, 17) Limited housing to place homeless under Rapid
     Rehousing, 18) Quarterly reporting, 19) Other funding available
  offering same service, 20) Income limits for homeless preventions
    are too low, 21) Earthquake sequence in the area, 22) Having to
    work remotely due to COVID-19, 23) Required to report through
             the Continuum of Care but not consult on activities, 24)
    Reluctance to do site-based reviews/monitoring, 25) Occupancy
 restrictions due to social distancing, 26) Guidelines around the use
                   of Rapid Rehousing (RRH) and Housing Prevention
                                                                                 Total   498 26      100% 27




25
   Listed by most to least common.
26
   The survey questionnaire allowed the 153 respondents that stated that they experienced challenges to check all
   of the challenges that applied to their agencies. As a result, there were 498 responses, as detailed in the
   Challenges table.
27
   There was a 1 percent difference due to rounding.

Emergency Solutions Grants CARES Act Program                                                             Page | 18
Office of Inspector General | U.S. Department of Housing and Urban Development
                                        Questions and selection choices                                                                                            Total                          Percentage



                                                                                   Challenges
    140                                                                                                                                                                                                30%
    120                                                                                                                                                                                                25%
                                                                                                      24%
    100                                                                                119
                                                                                                                                                                                                       20%
      80
                                                                            14%                                               14%                       15%                                            15%
      60                                                          69                                                  71                          73
                                                    10%                                                                                                                                           10% 10%
      40                         9%            52                                                                                                                                         52
                     45
      20                                                                                                                                                                                               5%
                                                                                                                                                                      17 3%
       0                                                                                                                                                                                               0%




                                                                                                                                                                    Travel restrictions
                                                                                                                                         Challenges coordinating
                                                             Project delays and
                                        Systems-technology

                                                                                    Capacity needs (for
                                                                                                             Planning challenges (for
              Fear of possible COVID-
                                                                                                                                                                                          Other
                                             issues and
                                                                                                              example, action plan,       with other sources of

                                                              additional costs
                                          communication

              19 and case resurgance                                              example, staff shortage)
                                                                                                             activity setup, reporting     funds (for example,
                                              problems
                                                                                                                  requirements)              CDBG, HOPWA)




 7. If Yes, how would you rate HUD’s program notices and
 waivers intended to help address the challenges listed in the
 prior question? For instance, HUD waived the requirement of
 having to submit the Consolidated Annual Performance and
 Evaluation Report (CAPER) within 90 days and extended it to
 180 days. Due to this waiver, it helped make it easier for your
 agency to be able to address one of its challenges if that
 challenge was capacity needs, because it allowed more time for
 your agency to complete the CAPER.
                                                                                                                    Very helpful                                    45                              29%
                                                                                                                                Helpful                             82                              54%
                                                                                                                       Not helpful                                  26                              17%
                                                                                                                                     Total                         153                              100%




Emergency Solutions Grants CARES Act Program                                                                                                                                                           Page | 19
Office of Inspector General | U.S. Department of Housing and Urban Development
                        Questions and selection choices                                      Total              Percentage



                               HUD's program notices and waivers

             Not helpful - 26 grant
               recipients (17%)




                                                                                           Helpful - 82 grant
                                                                                           recipients (54%)
                        Very helpful - 45
                        grant recipients
                             (29%)




 8. Does your agency need additional support from HUD to
 effectively administer the ESG-CV program during the COVID-19
 pandemic?

                                                                                  Yes          99                 32%
                                                                                   No         214                 68%
                                                                                 Total        313                 100%


                                      Additional support from HUD

                                                                                          Yes - 99 grant
                                                                                         recipients (32%)



                       No - 214 grant
                      recipients (68%)




Emergency Solutions Grants CARES Act Program                                                                         Page | 20
Office of Inspector General | U.S. Department of Housing and Urban Development
                        Questions and selection choices                                  Total    Percentage

 9. If Yes, what additional support is needed to effectively
 administer the ESG-CV program during the COVID-19 pandemic?
 Check all that apply.
                                                                   More training          42        27%
     More HUD assistance (such as HUD meetings to answer questions                        60        39%
      or concerns or providing remote technical assistance to address
                issues that were not anticipated from the pandemic)
     Other 28: 1) More time to build subrecipients’ capacity, 2) Maintain                 51        33%
      and more detailed HUD Technical Assistance, 3) More waivers, 4)
       Meeting quarterly reporting requirements and closer alignment
          with regular ESG reporting and tracking, 5) Make waivers and
          flexibilities automatic, 6) Continued evaluation of the ESG-CV
           program, 7) More training and detailed guidance, 8) Quicker
     response on AAQ and clear answers, 9) Waivers on the homeless
         definition, 10) Training that indicates how funds can be used in
       addition to rental payments, major renovation projects, 11) Less
        reporting via email, surveys, CAPER, IDIS, Sage, HMIS, and other
            mediums, 12) Direct assistance from HUD in explaining best
     practices and utilization of ESG-CV, 13) More time to spend funds
           and extend deadline, 14) A policy of some lenience in future
                  monitoring during this time period, as long as agencies
         demonstrate good-faith and reasonable efforts to comply with
                                                                    rules
                                                                                 Total   153 29    100% 30
 10. Does your agency anticipate future challenges in
 administering the ESG-CV program as a result of the COVID-19
 pandemic and its impact on program operations?
                                                                                  Yes    130        42%
                                                                                   No    183        58%
                                                                                 Total   313        100%




28
   Listed by most to least common.
29
   The survey questionnaire allowed the 99 respondents that needed additional support from HUD to check all
   types of support needed. As a result, there were 153 responses.
30
   There was a 1 percent difference due to rounding.

Emergency Solutions Grants CARES Act Program                                                           Page | 21
Office of Inspector General | U.S. Department of Housing and Urban Development
                        Questions and selection choices                            Total            Percentage



                                    Anticipating future challenges



                                                                                  Yes - 130 grant
                    No - 183 grant                                               recipients (42%)
                   recipients (58%)




 11. If Yes, what are the anticipated future challenges in
 administering the ESG-CV program that your agency anticipates
 as a result of the COVID-19 pandemic and its impact on program
 operations?
              Continued fear of possible COVID-19 and case resurgence                48               12%
             Continued systems-technology issues and communication                   24                6%
                                                         problems
                            Continued project delays and additional costs            59               15%
                           Continued capacity needs (e.g. staff shortage)            95               24%
        Continued planning challenges (e.g. action plan, activity set up,            59               15%
                                              reporting requirements)
        Continued challenges coordinating with other sources of funds                59               15%
                                                 (e.g. CDBG, HOPWA)
                                                 Continued travel restrictions       10                2%
      Other 31: 1) State of the housing market due to COVID-19 such as               48               12%
        extension of eviction moratorium, eligibility tenant protections,
        landlord participation with Rapid Rehousing programs, building
     occupancy restrictions due to social-distancing, inspecting sites for
          rental activities, 2) Lack of affordable housing, 3) Expenditure
         deadline, 4) Coordination or competing with similar services of
                other funds such as FEMA funds, Treasury EGA funding,


31
      Listed by most to least common.

Emergency Solutions Grants CARES Act Program                                                             Page | 22
Office of Inspector General | U.S. Department of Housing and Urban Development
                        Questions and selection choices                                  Total              Percentage

          duplication of benefits, 5) Capacity needs such as grantee and
     subrecipient staff time due to illness, 6) Stringent program notices
       and guidance needing revision and special permission from HUD
            on changes to scope outside amending the action plan and
        continue to commit funds, 7) Construction delays, 8) Continued
      grantee conclusion due to administrative changes and challenges
               that have put into place as well between ESG and ESG-CV
              identifying more subrecipients willing to participate in the
         program, 9) Continued challenges with affordable housing and
         needs after funding ends 2022, 10) Not being able to use relief
              dollars for marketing to “get the word out”, 11) Quarterly
                                                                reporting
                                                                                 Total   402 32              100% 33
 12. Did your agency receive other sources of non-HUD funding
 (e.g. Federal Emergency Management Agency, state, and local)
 to address homelessness?
                                                                                  Yes    197                  63%
                                                                                   No    116                  37%
                                                                                 Total   313                  100%


                                                Non-HUD funding
                 No - 116 grant
                recipients (37%)




                                                                                          Yes - 197 grant
                                                                                         recipients (63%)




32
   The survey questionnaire allowed the 130 respondents to check all the applicable anticipated future challenges
   in administering the ESG-CV program that their agency anticipated as a result of the COVID-19 pandemic and its
   impact on program operations. As a result, there were 402 responses.
33
   There was a 1 percent difference due to rounding.

Emergency Solutions Grants CARES Act Program                                                                     Page | 23
Office of Inspector General | U.S. Department of Housing and Urban Development
                        Questions and selection choices                                        Total           Percentage

 13. If yes, to what extent has receiving other source of non-HUD
 funding impeded your spending of ESG-CV funds?
                                                                              Minor             39               20%
                                                                        Moderate                68               35%
                                                                        Significant             57               29%
                                                                           No effect            33               17%
                                                                                 Total         197              100% 34


                                        Impact of non-HUD funding

       No effect                   39 grant recipients (20%)



      Significant                                               57 grant recipients (29%)



      Moderate                                                                68 grant recipients (35%)



          Minor                        33 grant recipients (17%)


                    0         10           20            30           40            50         60         70        80




 14. Did your agency grant ESG-CV funds to subrecipients to
 administer?
                                                                                  Yes          273               87%
                                                                                   No           40               13%
                                                                                 Total         313               100%




34
     There was a 1 percent difference due to rounding.

Emergency Solutions Grants CARES Act Program                                                                        Page | 24
Office of Inspector General | U.S. Department of Housing and Urban Development
                        Questions and selection choices                                     Total           Percentage


                        Provided ESG-CV funds to subrecipients

                             No - 40 grant
                           recipients (13%)




                                                                                          Yes - 273 grant
                                                                                         recipients (87%)




 15. If Yes, to what extent has the COVID 19 pandemic impacted
 your agency’s ability to effectively monitor the ESG-CV program
 being administered by subrecipient(s)?

                                                                             Minor           57               21%
                                                                        Moderate            114               42%
                                                                        Significant          57               21%
                                                                         No effect           45               16%
                                                                                 Total      273               100%




Emergency Solutions Grants CARES Act Program                                                                     Page | 25
Office of Inspector General | U.S. Department of Housing and Urban Development
                        Questions and selection choices                                          Total                Percentage



                                Impact on monitoring subrecipients

      No effect              45 grant recipients (16%)




     Significant                       57 grant recipients (21%)




     Moderate                                                                            114 grant recipients (42%)




         Minor                         57 grant recipients (21%)



                   0              20                40               60                  80               100             120




 16. Does your agency expect to use a majority or all of its ESG-
 CV funds by the spending deadline of September 30, 2022?
 Check all that apply.
                                                  Yes, all funding will be used                    96                   24%
                                   Yes, a majority of the funds will be used                      115                   29%
                                         Yes, but extensions may be needed                        156                   39%
            No, significant amounts will remain unused due to various                              31                    8%
                                                          challenges
      No, significant amounts will remain unused due to lack of need                               4                     1%
                                                                                 Total           402 35                100% 36




35
   The survey questionnaire allowed the 130 respondents to check all applicable anticipated future challenges in
   administering the ESG-CV program that their agency anticipated as a result of the COVID-19 pandemic and its
   impact on program operations. As a result, there were 402 responses.
36
   There was a 1 percent difference due to rounding.

Emergency Solutions Grants CARES Act Program                                                                               Page | 26
Office of Inspector General | U.S. Department of Housing and Urban Development
                          Questions and selection choices                                     Total             Percentage



                                                  Spending Deadline
                                                 September 30, 2022
     180                                                                                                             45%
                                                                      39%
     160                                                                                                             40%
     140                                      29%                                                                    35%
     120                                                        156                                                  30%
                          24%
     100                                                                                                             25%
                                           115
       80            96                                                                                              20%
       60                                                                                                            15%
       40                                                                                8%                          10%
       20                                                                                              4             5%
                                                                                    31                     1%
        0                                                                                                            0%
            Yes, all funding will   Yes, a majority of   Yes, but extensions   No, signficant     No, significant
                  be used           the funds will be      may be needed amounts will remain amounts will remain
                                           used                                unused due to    unused due to lack
                                                                             various challenges      of need




Emergency Solutions Grants CARES Act Program                                                                         Page | 27
Office of Inspector General | U.S. Department of Housing and Urban Development


File and source

File
hud-oig-2022-la-0002.pdf
Size
1,044,713 bytes
SHA-256
ebb1807f2ce345a4169f3bd2ccaa321bb87b2e6fbe6ce59fa0129748f7014f67
Our copy
hud-oig-2022-la-0002.pdf
Original
www.hudoig.gov
Back to top