ESG Recordkeeping Requirements
HUD’s CoC and ESG Interim Rule establish recordkeeping requirements and order of priority for verifying homeless status. To help agencies ensure compliance with these requirements, the Pasadena Partnership has established a standardized set of Recordkeeping Forms. All agencies receiving ESG-funding who are serving homeless clients should use the Homeless Status Verification Forms to ensure program eligibility. Agencies that receive Rapid Re-Housing funding should use the Rapid Re-Housing forms in addition to the Homeless Status Verification Forms to ensure program eligibility.
Homeless Status Verification Forms
In order of preference for documenting homeless status (as detailed by HUD), Pasadena Partnership’s Homeless Status Verification Forms include:
- HMIS Records (Updated HMIS Participant Organization Agreement and Interagency Data Sharing Consent Form are both required to verify individual clients)
- Written Third Party Verification of Homeless Status
- Observation of Homeless Status by Outreach Worker
- Oral Third Party Verification of Homeless Status
- Self-Declaration of Homeless Status
Rapid Re-Housing Eligibility Forms
For Rapid Re-Housing programs, additional documentation is required to verify program eligibility. This documentation includes:
HUD Recordkeeping Requirements
For more information on HUD’s recordkeeping requirements, see:
- CoC Interim Rule (24 CFR 578)
- ESG Interim Rule (24 CFR 576)
- Notice on Prioritizing Chronically Homeless (Notice CPD-14-012)
- HEARTH Homeless Definition Final Rule (583.301(b))