ESG FAQ
Q

If an ESG case manager learns that a program participant’s annual income has increased and now exceeds 30% of AMI, must the recipient/subrecipient immediately stop providing assistance to the program participant?

Date Published: December 2012

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A

Whether a recipient/subrecipient must stop a program participant’s ESG assistance upon learning of an increase in income (or other change in household circumstances that may affect eligibility) depends upon whether the information is obtained through a re-evaluation, or through other means (e.g., case management). 

If income over AMI is discovered during re-evaluation for homelessness prevention and rapid re-housing assistance:  Each re-evaluation of eligibility must establish that the program participant has an annual income that does not exceed 30 percent of median family income for the area, as determined by HUD. (24 CFR § 576.401(b)(1)(i)).  Rapid Re-Housing program participants must be re-evaluated not less than once annually and Homelessness Prevention program participants must be re-evaluated not less than once every three months. If the re-evaluation shows that the program participant is no longer eligible for ESG, assistance must be stopped at that time.  

If income over AMI is discovered outside of the re-evaluation process for homelessness prevention and rapid re-housing assistance:  HUD does not require recipients/subrecipients to conduct a re-evaluation outside of the regular re-evaluation process if information becomes available to indicate that a household has (or may have) increased income or a change in household circumstances that affect eligibility for the program.  However, the recipient/subrecipient has discretion to institute its own standards and MAY require each program participant receiving Rapid Re-Housing or Homelessness Prevention assistance to provide information about changes in income or other circumstances (e.g., household composition) that affect the program participant’s need for assistance. When a program participant notifies a recipient/subrecipient of a relevant change because the notification is REQUIRED, the recipient/subrecipient MUST re-evaluate the program participant’s eligibility and the amount and types of assistance the program participant needs (see 24 CFR § 576.401(b)(2)). If the re-evaluation shows that the program participant is no longer eligible for ESG, assistance must be stopped at that time.  

If the recipient/subrecipient has NOT required such a notification, simply receiving information about a change in a program participant's situation outside of the re-evaluation process (e.g., through case management or credit repair activities) has no immediate effect on the program participant’s eligibility for ESG, and ESG assistance can continue until the next re-evaluation. At that time, the re-evaluation will determine whether the program participant continues to be eligible for ESG assistance.


Tags: ESG Program Requirements - Eligible Participants

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