Date Published: December 2012
Yes, under the ESG program, you are required to keep a record of all clients that are screened and classified as ineligible. The ESG recordkeeping and reporting requirements state that for each individual and family determined ineligible to receive ESG assistance, the record must include documentation of the reason for that determination. (See 24 CFR § 576.500(d)).
With regard to entering data into an HMIS, the ESG regulation does not require that data about individuals or families determined to be ineligible be entered into an HMIS. (See 24 CFR § 576.400(f)). However, recipients/subrecipients MAY use an HMIS to retain this information if they wish to do so. In addition, HUD provides recipients with considerable discretion in designing their local program requirements. So a recipient may require its subrecipients to report on these individuals or families in an HMIS, and this should be tracked under either outreach/engagement or case management. Note that if individuals or families who are determined ineligible are reported in an HMIS, it is important that they NOT be included when reporting to HUD on persons assisted with ESG funds.
Subrecipients should be sure to check with their local recipient to find out about any local policies governing recordkeeping and reporting requirements.