The U.S. Department of Housing and Urban Development (HUD) is announcing the issuance of the Emergency Solutions Grant (ESG) notice for additional public comment on the interim rule, Emergency Solutions Grants (ESG) Program; Solicitation of Comment on Specific Issues.

This is the second time HUD is opening the ESG interim rule for public comment, before issuing the final rule. The first comment period for the interim rule ended on February 3, 2012. HUD has carefully reviewed all comments received in response to the interim rule through the first comment period. However, because recipients and sub-recipients have now had more experience implementing the interim rule, HUD recognizes that they may have additional input and comments to consider in its development of the ESG final rule. HUD greatly appreciates and values the feedback that commenters provide and especially seeks feedback that draws on their experience with the interim rule. Therefore, HUD is issuing this notice to re-open the public comment period for an additional 60 days. The comment period will close on Monday, August 3, 2015.

HUD requests that commenters not resubmit any comments already submitted in the first public comment period unless they provide new information or insights based on research or experience with the program as HUD will consider comments from both comment periods when drafting the Final Rule.

The instructions for submitting comments are outlined in the beginning of the notice. Please review this section carefully; note that all comments must be submitted in the manner outlined in the notice for HUD to consider the comment. Do not submit questions or comments about the notice to the Ask A Question help desk on HUD Exchange (AAQ) as the AAQ cannot answer questions about the notice. If a requirement in the Notice is unclear, please submit that as a comment.

In this notice, HUD is seeking additional feedback and comment on certain, limited provisions of the ESG interim rule. In many instances, HUD proposes specific language for comment. Many of the specific areas on which HUD has identified for additional comment are based on feedback HUD has received via the AAQ, at conferences, and in discussions with recipients, sub-recipients, and other stakeholders. HUD has published an outline of the notice, to provide an at-a-glance overview of the content to readers. Readers can use the outline to help them follow along and as a tool to organize the final comments that they will submit.

In general, as you are reading the notice and considering comments to submit, HUD asks you to think about the following questions for each of the changes being considered:

• How will it affect individuals and families who are homeless and at risk of homelessness, who this program is designed to serve?
   
• Will it assist with ease of administering the program?
   
• Will it help improve compliance with the regulation?
   
• What effects could it have in your community - both positive and negative?

Finally, this notice does not establish any new requirements. The ESG interim rule is in effect until the ESG final rule is published. All of the proposed language and topics are presented only for consideration at this time.

HUD greatly appreciates your time and attention to providing helpful and constructive comments to improve the ESG program for the final rule.

The 2015 new and conversion project guidelines and pre-application for the Kentucky Balance of State (BoS) Continuum of Care (CoC) are now available. Agencies that submitted a new project intent to apply in May should use the 2015 Kentucky BoS CoC New and Conversion Project Guidelines/Pre-Application to complete the next step in the 2015 CoC application process.

Current CoC-funded Transitional Housing (TH) or Support Service Only (SSO) projects, needing to renew CoC funding in 2015, are the only entities eligible to apply for project conversion funding. Only conversion to Rapid Rehousing Housing (RRH) for individuals or families, or Permanent Supportive Housing (PSH) dedicated to chronically homeless, will be permitted. TH or SSO programs that are changing program components to PSH or RRH will be given priority in reallocation funding over other new project applications.

Applicants should ensure their proposed project conversions will serve at least as many households annually as their current CoC project. All conversion projects will be scored using the renewal project scoring criteria.

To assist in preparing a pre-application with a leasing or rental assistance budget, a 2015 Leasing/Rapid Rehousing FMR Worksheet is also available online with 2015 Fair Market Rents (FMRs) linked in the document.

The 2015 KY BoS CoC New Project Scoring Criteria is also available.

All new projects applying for KY BoS CoC reallocation funding or any new funding that may be announced via the 2015 Notice of Funding Availability (NOFA) will be using the 2015 KY BoS CoC New Project Scoring Criteria.

The 2015 CoC NOFA may be released during the process of completing the pre-application. The NOFA will provide the HUD-required process for the HUD CoC application, including the application deadline. It will also specify eligible projects and HUD priorities. The 2015 KY BoS funding priorities are based on current state and federal homeless goals and should not vary with the 2015 NOFA.

All necessary documents are available on KHC's website, under Specialized Housing, Continuum of Care.

All parties interested in submitting new or conversion projects must submit a pre-application to Ruth Ann Cooper via email at rcooper@kyhousing.org by 5 p.m., Monday, August 10, 2015.   

All entities applying for new, conversion, or renewal grant funds through the 2015 Kentucky BoS CoC are required to complete a 2015 CoC Capacity Scorecard and Fair Housing Survey for EACH project.This information will be used in the overall statewide ranking for the 2015 Kentucky BoS CoC Project Priority Listing submitted to HUD. 

Additional CoC-specific questions have been added to the 2015 CoC Capacity Scorecard that align with HUD's project threshold.

New for this year, all entities applying for funds through the 2015 CoC application process are require to complete a Fair Housing Survey for each project administered by entity. If an entity cannot demonstrate that a new or renewal project will address one of the impediments, the project may not be allowed to move forward in application process or may have funds reallocated to another project. 

For more information about KHC's fair housing publication, Our Right to Choose Where We Live:  Analysis to Impediments, is available on KHC's website, under Resources, Data Library, or on KHC's YouTube Channel. 

The 2015 CoC Capacity Scorecard and Fair Housing Survey is available on KHC's website, under Specialized Housing, Continuum of Care. Please note, the scorecard is the first tab in the Excel document and the survey is the second tab.

If you have any questions or need technical assistance, please contact Lynn Chrisman at 270-519-4422 or email lchrisman@kyhousing.org.

Please complete the 2015 CoC Capacity Scorecard and Fair Housing Survey by Monday, July 20, 2015, and email the survey to lchrisman@kyhousing.org.  

Norm Suchar, Director of the HUD Office of Special Needs Assistance Programs (SNAPS), recently released information regarding the upcoming FY 2015 CoC NOFA, which is expected to be announced in July 2015. Suchar outlined the following information for the FY2015 CoC application cycle:

• A More Competitive Process: HUD expects to have enough funding for FY 2015 to award all renewal projects; however, they are still implementing a tiered funding process. Tier 1 will be a smaller percentage than in years past, and the process for selecting projects from Tier 2 will be much more competitive. Whether a project is funded will depend much more on the performance of the CoC and the qualities of the project.
   
• Rewards for CoCs Implementing Strategies Consistent with Opening Doors:  In FY 2015, HUD will be more aggressively promoting the strategies outlined in Opening Doors. This includes demonstrating progress towards strategic resource allocation; ending chronic, family, veteran, and youth homelessness; and implementing housing first approaches.
   
• Expanded Reallocation Opportunities:  This year, HUD is expanding reallocation to allow CoCs to fund projects that enhance data collection and analysis along with coordinated entry. During the FY 2015 Competition, CoCs will be able to reallocate to the following types of projects:
• Permanent Supportive Housing for chronically homeless households, including individuals, families, and unaccompanied youth.
• Rapid Re-housing for individuals and families, including unaccompanied youth, who are residing on the streets or in emergency shelters or who are fleeing domestic violence.
• Dedicated HMIS.
• Supportive Service Only for Coordinated Entry.

For more information and list of resources, please read the full article from SNAPS.  

Kentucky Homeless Management Information System (KYHMIS) users will soon be able to access their invoices online! KHC is working with PNC Bank to use Automated Clearing House (ACH) to accept payment.  

As of July 1, 2015, Lexington CoC and BoS CoC may access the ACH system at:  https://www.payerexpress.com/ebp/KHC/. Select "Pay Now" for a one-time easy payment option. Your account number is your KYHMIS Agency Provider ID number. If you need to locate this number, please contact your agency's KYHMIS Subject Matter Expert. You will need your agency bank account number and bank routing number. If you have multiple accounts, please make sure that this is the account number that you wish to use to pay the specific invoice. Print your receipt for your agency's record keeping purposes. There is a print option on this page, so please make sure that you print the receipt prior to exiting the menu. For more directions on how to use the ACH system, please select HELP at the bottom of the main menu screen.   

The Louisville CoC has already had billing processed and will not need to access the ACH system at this time.

All required forms will be available online for download and submission to KHC electronically.

KYHMIS user license fees are due by Friday, July 31, 2015. Late fees of 10 percent will be assessed on unpaid balances beginning Saturday, August 1, 2015. Late fees of 20 percent will be assessed on unpaid balances beginning Tuesday, September 1, 2015. If license fees are not paid by Thursday, October 1, 2015, agency usage in the KYHMIS will be suspended.

If you have any questions, please contact Lena Columbia toll-free in Kentucky at 800-633-8896 or 502-564-7630, extension 448; TTY 711; or email lcolumbia@kyhousing.org.

This year, KYHMIS users will be able to submit the annual required documentation online! The following four documents must be signed and submitted by selecting Submit a Request within the HCA Help Desk by Monday, August 3, 2015, to remain compliant with KYHMIS:

• 2015 KYHMIS External Policies and Procedures 
• 2015 KYHMIS Participation Agreement 
• 2015 Security Monitoring Form (one per agency)
• 2015 KYHMIS User Confidentiality Agreement 

Failure to submit the required documentation by Monday, August 3, 2015, may result in agency licenses being suspended and/or withholding of draws until compliant.

The KYHMIS Privacy Notice has also been updated. All KYHMIS agencies are responsible for ensuring the current KYHMIS Privacy Notice and Privacy Policy are posted and available to all clients. These documents are available on the HCA Help Desk.

The updated KYHMIS External Policies and Procedures are now in effect. Slight changes have been made for clarification purposes. The document is available on the HCA Help Desk. KHC asks partners to review the document and reference it when addressing roles, responsibilities, and liabilities for their agency, users, and clients.

If you have questions, please contact Anne Colly Rose toll-free in Kentucky at 800-633-7630 or 502-564-7630, extension 259; TTY 711; or email arose@kyhousing.org.