CDBG Entitlement FAQ

When carrying out activities that benefit homeless persons, is the CDBG grantee (or subrecipient) required to ensure that the beneficiaries met the categories of definitions of homeless at 24 CFR 91.5 in connection with the Homeless Emergency Assistance and Rapid Transition to Housing (HEARTH) Act?

Date Published: April 2019

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No. The CDBG program allows grantees to define "homeless" for presumed low- and moderate-income benefit activities. The CDBG regulations and the CDBG Guide to National Objectives and Eligible Activities for Entitlement Communities do not define "homeless persons". However, the Consolidated Plan regulations do, and the CDBG program is one of the programs covered by the Consolidated Plan; but the Consolidated Plan regulations govern the development of the Plan and the submission requirements, not necessarily the implementation of specific activities under specific programs.

When identifying the needs of its homeless population and the goals to address those needs in the Consolidated Plan, the grantee may use the definitions of "at risk of homelessness," "chronically homeless," "homeless," "homeless under other Federal statutes," and "women fleeing domestic violence" at 24 CFR 91.5. In addition, persons falling into any of these categories except "at risk of homelessness" will meet the low- and moderate-income limited clientele presumed benefit criterion at 24 CFR 570.208(a)(2)(i)(A) for Entitlements and 24 CFR 570.483(b)(2)(ii)(A) for States. Persons at risk of homelessness cannot meet this presumption because there is no data demonstrating that persons falling into this category are low- and moderate-income. See FAQ 3611

Tags: CDBG Entitlement Program Homeless

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