The McKinney-Vento Framework for Homeless Assistance
The McKinney-Vento Homeless Assistance Act (42 U.S.C. 11301 et seq.), first enacted in 1987 and substantially amended by the HEARTH Act (Homeless Emergency Assistance and Rapid Transition to Housing) in 2009, is the primary federal legislation addressing homelessness in the United States. It authorizes two principal grant programs administered by HUD's Office of Special Needs Assistance Programs (SNAPS): the Continuum of Care (CoC) program and the Emergency Solutions Grants (ESG) program.
Together, these programs provide approximately $3.6 billion annually to fund the nation's homeless assistance infrastructure. The CoC program accounts for roughly $3 billion through competitive awards, while ESG distributes approximately $600 million by formula to states and entitlement jurisdictions. Understanding how these two programs interact — and where they differ — is essential for any organization operating within the homeless services system.
Two Programs, One System: CoC and ESG
The CoC and ESG programs serve complementary functions within a community's homeless response system. ESG provides the front-door crisis response — street outreach, emergency shelter, homelessness prevention, and rapid re-housing. CoC provides the longer-term housing solutions — permanent supportive housing, rapid re-housing at scale, transitional housing, supportive services, and HMIS. HUD expects these programs to be coordinated through the local Continuum of Care planning body.
| Dimension | CoC (CFDA 14.267) | ESG (CFDA 14.231) |
|---|---|---|
| Award mechanism | Competitive annual competition | Formula to states and entitlement cities |
| Annual funding | ~$3 billion | ~$600 million |
| Primary components | PSH, RRH, TH, Joint TH-RRH, SSO, HMIS | Street outreach, emergency shelter, prevention, RRH, HMIS |
| Match requirement | 25% (except leasing) | 100% dollar-for-dollar |
| Reporting | APR in SAGE, SPMs, PIT, HIC | CAPER, PIT, HIC |
| Federal administrator | HUD SNAPS | HUD SNAPS (through CPD field offices) |
| Regulatory authority | 24 CFR Part 578 | 24 CFR Part 576 |
CoC Program Component Types
The CoC program funds several distinct component types, each serving a different function in the homeless response system. Understanding these components is fundamental to navigating eligibility, application, and compliance requirements.
- Permanent Supportive Housing (PSH): Long-term housing with wraparound supportive services for chronically homeless individuals and families. PSH is HUD's highest priority component because evidence demonstrates it is the most effective intervention for chronically homeless populations. PSH participants have no time limit and cannot be terminated from housing for failure to participate in services.
- Rapid Re-Housing (RRH): Short- to medium-term rental assistance and services to help individuals and families quickly exit homelessness and return to permanent housing. RRH assistance is time-limited (typically up to 24 months) and designed to be the primary intervention for most homeless households.
- Transitional Housing (TH): Temporary housing (up to 24 months) with supportive services. HUD has de-prioritized standalone TH in favor of PSH and RRH, and new TH projects are rarely funded. Existing TH projects face scrutiny on performance and are often encouraged to convert to Joint TH-RRH or RRH.
- Joint TH-RRH: A combined component that allows participants to move from a transitional housing placement directly into rapid re-housing with the same project. This component was created to maintain some transitional housing capacity while linking it to a permanent housing outcome.
- Supportive Services Only (SSO): Funding for services (case management, outreach, employment assistance, behavioral health referrals) without an associated housing component. SSO projects serve people experiencing homelessness or those in permanent housing to prevent returns to homelessness.
- HMIS: Funding for the Homeless Management Information System that the CoC uses to collect, manage, and report client-level data. Each CoC designates one HMIS lead agency.
The Continuum of Care Structure
Every community in the United States is covered by one of approximately 400 Continuums of Care. The CoC is not a single organization but a planning body that coordinates the community's homeless response system. Understanding the CoC structure is essential because your organization's relationship to the CoC determines your access to funding, your reporting obligations, and your compliance requirements.
- Collaborative applicant: The entity designated by the CoC to submit the CoC Application to HUD on behalf of the entire continuum. This is typically a nonprofit, government agency, or planning coalition. The collaborative applicant manages the local competition, assembles the priority listing, and coordinates with HUD throughout the grant process.
- HMIS lead agency: The entity responsible for operating the local Homeless Management Information System. The HMIS lead ensures data quality, manages user access, provides training, and generates the reports required by HUD (APR, SPMs, PIT data, HIC data).
- CoC board/governance: The governance structure that sets priorities, reviews and ranks projects in the local competition, oversees coordinated entry, and makes strategic decisions about the community's homeless response. HUD requires CoC governance to include representation from homeless or formerly homeless individuals.
- Project applicants/recipients: The individual organizations that operate CoC-funded projects (PSH, RRH, TH, SSO, HMIS). These organizations apply through the local competition and, if funded, enter into grant agreements with HUD.
HUD's Housing First Approach
Housing First is not merely a preference in HUD homeless assistance — it is a core operating principle that affects competitive scoring, compliance reviews, and monitoring outcomes. The Housing First approach holds that permanent housing is the foundation upon which other life improvements are built, and that access to housing should not be contingent on sobriety, treatment compliance, income level, or service participation.
In the CoC competition, HUD scores projects on their adherence to Housing First principles. Projects that impose preconditions on program entry, require participation in services as a condition of continued housing, or terminate participants for non-compliance with program rules (rather than lease violations) score lower and may be ranked below other projects in the local competition. For PSH in particular, Housing First fidelity is a primary evaluation criterion.
Point-in-Time Count and Housing Inventory Count
Two community-level data collection activities define the scope and scale of homelessness in each CoC and drive funding and policy decisions:
- Point-in-Time (PIT) Count: A one-night count of people experiencing homelessness, conducted during the last ten days of January. Sheltered PIT counts are required annually; unsheltered counts are required biennially (odd-numbered years). The PIT count produces the most widely cited national homelessness statistics and directly informs CoC funding decisions.
- Housing Inventory Count (HIC): An annual inventory of beds and units available in a CoC for people experiencing homelessness, including emergency shelter, transitional housing, rapid re-housing, permanent supportive housing, and other permanent housing. The HIC provides the denominator for utilization rate calculations that affect CoC competition scoring.
Who This Guide Is For
This Homeless Assistance Program Guide is written for practitioners working within the CoC and ESG system:
- CoC Lead Agency and Collaborative Applicant Staff responsible for the annual competition, system coordination, and HUD reporting
- Project Directors and Program Managers operating PSH, RRH, TH, SSO, or HMIS projects funded through CoC or ESG
- HMIS Administrators and Data Analysts managing data quality, reporting, and system performance measurement
- Grants Managers and Fiscal Officers handling CoC and ESG budgets, match documentation, and financial reporting
- ESG Recipients and Subrecipients administering formula-based emergency solutions grants at the state, city, or provider level
What This Guide Covers
Each section of this guide addresses a specific aspect of homeless assistance program management. Whether you are a first-time CoC applicant or an experienced program director preparing for HUD monitoring, these pages provide the detailed reference information you need.