CoC & ESG Eligibility Requirements

Understanding Eligibility in the CoC/ESG System

Eligibility for HUD homeless assistance operates at three levels: organizational eligibility (who can apply), project eligibility (what types of projects can be funded), and participant eligibility (who can be served). Each level has distinct requirements, and confusion between them is a common source of compliance problems. This guide addresses all three levels for both the Continuum of Care (CoC) program and the Emergency Solutions Grants (ESG) program.

CoC Registration and Geographic Coverage

Before any organization can receive CoC funding, it must be part of a registered Continuum of Care. HUD requires every geographic area in the United States to be covered by a CoC, and there are approximately 400 registered CoCs. Each CoC has a unique identification number (e.g., WA-500, CA-600) and a defined geographic boundary.

CoCs must register annually with HUD through e-snaps to participate in the CoC competition. Registration requires the CoC to designate a collaborative applicant, identify an HMIS lead, and demonstrate that it meets the organizational and planning requirements under 24 CFR 578. A CoC that fails to register cannot submit an application, and the projects within its geographic area cannot receive CoC funding for that competition cycle.

Eligible Applicants: CoC Program

The CoC program has broad organizational eligibility. Under 24 CFR 578.15, the following entity types are eligible to apply as project applicants:

• Nonprofit organizations: 501(c)(3) organizations are the most common CoC recipients. This includes homeless service providers, housing organizations, behavioral health agencies, community action agencies, and faith-based organizations (operating through separate secular entities where required).
• State governments: State agencies may apply for CoC funding, though this is less common than nonprofit applicants. State housing finance agencies or departments of human services sometimes apply for statewide or regional projects.
• Local governments: Cities, counties, and other units of local government are eligible. Many CoCs include government-operated projects, particularly for HMIS and coordinated entry.
• Public housing agencies (PHAs): PHAs can apply for CoC funding and often partner with CoC projects through housing authority vouchers and public housing units.
• Instrumentalities of state and local governments: Government-created entities such as housing authorities, redevelopment agencies, and planning commissions.
• Tribal organizations and tribally designated housing entities (TDHEs): Federally recognized tribes and their designated housing entities are eligible to apply for CoC funding, either within a geographic CoC or through dedicated tribal CoCs.

Important: For-profit entities are not eligible to apply directly for CoC grants. However, for-profit entities may serve as subrecipients or contractors to eligible CoC recipients.

The Collaborative Applicant Role

Each CoC designates one entity as its collaborative applicant. This entity plays a unique and critical role in the CoC program:

• Submits the CoC Application to HUD, including the CoC Registration, CoC Consolidated Application, CoC Priority Listing, and all project applications
• Manages the local competition process, including timelines, application review, and project ranking
• May apply for CoC planning costs (up to 3% of the CoC's annual award) to fund system coordination activities
• May apply to be the Unified Funding Agency (UFA), which allows the collaborative applicant to receive and distribute all CoC funds within the continuum

The collaborative applicant is typically a nonprofit organization, government agency, or coalition that has the administrative capacity to manage the complex CoC application process. In many communities, this is the same entity that serves as the HMIS lead, though HUD does not require this.

Project Eligibility by Component Type

Not every eligible applicant can operate every component type. The CoC NOFO and 24 CFR 578 specify which activities are eligible under each component, and the CoC's local priorities determine which component types are included in the annual competition.

Participant Eligibility: HUD Homeless Definitions

HUD's definition of homelessness under 24 CFR 578.3 and the HEARTH Act establishes four categories. The category under which a participant qualifies determines which CoC and ESG components may serve them and what documentation is required.

Category 1: Literally Homeless

An individual or family who lacks a fixed, regular, and adequate nighttime residence, meaning they are living in:

• A place not designed for or ordinarily used as a regular sleeping accommodation (cars, parks, abandoned buildings, bus stations, airports, camping grounds)
• A supervised publicly or privately operated emergency shelter, including transitional housing for people who originally came from the street or shelter
• An institution (hospital, jail, substance abuse treatment facility) where they have resided for 90 days or fewer and were in an emergency shelter or unsheltered location immediately before entering the institution

Category 1 is the primary eligibility category for most CoC components. PSH projects serving chronically homeless individuals must serve Category 1 participants who also meet the chronically homeless definition.

Category 2: Imminent Risk of Homelessness

An individual or family who will imminently lose their primary nighttime residence within 14 days, has no subsequent residence identified, and lacks the resources or support networks needed to obtain other permanent housing. This category requires documentation that the loss of housing is imminent (eviction notice, court order, lease termination) and that no alternative housing has been identified.

Category 2 is primarily served by ESG homelessness prevention activities and is generally not eligible for CoC-funded housing components.

Category 3: Homeless Under Other Federal Statutes

Unaccompanied youth under 25 years of age, or families with children and youth, who are defined as homeless under other listed federal statutes and who have experienced a housing instability pattern. This category has limited applicability in the CoC program — only projects specifically designated to serve this population and with prior HUD approval may use Category 3 eligibility.

Category 4: Fleeing Domestic Violence

Any individual or family who is fleeing, or attempting to flee, domestic violence, dating violence, sexual assault, stalking, or other dangerous or life-threatening conditions that relate to violence against the individual or family member. This category does not require the individual to meet the literal homelessness definition under Category 1 — the act of fleeing creates the eligibility.

Category 4 participants are eligible for CoC RRH, Joint TH-RRH, and TH components, as well as ESG rapid re-housing and emergency shelter. Domestic violence service providers may use a comparable database instead of HMIS to protect participant confidentiality.

The Chronically Homeless Definition

The chronically homeless definition (24 CFR 578.3) is critical because HUD prioritizes PSH for this population, and dedicated chronically homeless PSH beds must serve individuals who meet this specific definition:

• Individual: A homeless individual with a disability who has been continuously homeless for at least 12 months, OR has had at least 4 episodes of homelessness in the last 3 years where the combined length of time is at least 12 months. Each episode must have been separated by a break of at least 7 nights.
• Family: A family with an adult head of household (or minor head of household if no adult is present) who meets the individual chronically homeless definition.

The "disability" component requires documentation of a diagnosable substance use disorder, serious mental illness, developmental disability, post-traumatic stress disorder, cognitive impairments resulting from a brain injury, or chronic physical illness or disability. Disability documentation must come from a qualified professional. The "homelessness" component requires documentation of the duration and episodes from HMIS, third-party verification, or self-certification (as a last resort).

Chronic homelessness documentation is one of the most frequently audited areas in CoC monitoring. See the Common Mistakes guide for specific documentation pitfalls.

ESG Recipient Eligibility

ESG uses a different eligibility structure than CoC because it is a formula grant rather than a competitive award. ESG funds flow directly from HUD to two types of recipients:

Entitlement Jurisdictions

Metropolitan cities and urban counties that receive Community Development Block Grant (CDBG) entitlement allocations above a minimum threshold also receive ESG formula allocations. These jurisdictions receive ESG funds directly from HUD and administer them locally, either through their own programs or by subgranting to nonprofit service providers.

States

Each state receives an ESG allocation covering the non-entitlement areas within the state (areas not covered by a metropolitan city or urban county ESG allocation). States typically subgrant these funds to nonprofit organizations and local governments through a competitive or formula-based process.

ESG Subrecipient Eligibility

ESG recipients (states and entitlement jurisdictions) may subgrant ESG funds to eligible subrecipients. Eligible subrecipients include:

• Units of general purpose local government
• Private nonprofit organizations (including faith-based organizations operating through secular entities)
• Public nonprofit organizations

ESG subrecipients must participate in the local CoC's coordinated entry system and HMIS. This requirement ensures that ESG-funded activities are integrated with the broader homeless response system rather than operating independently.

Registration and System Requirements

Organizations applying for CoC or ESG funding must maintain several registrations and system access credentials. The SAM.gov registration guide covers the general requirements for federal grant recipients. Key system requirements for homeless assistance programs include:

• SAM.gov: Active registration with current Unique Entity Identifier (UEI) required for all CoC applicants
• e-snaps: HUD's electronic grants management system. All CoC project applicants must register in e-snaps and submit project applications through this system.
• HMIS: All CoC and ESG recipients must participate in the local HMIS (or comparable database for DV providers). HMIS access must be established before project operations begin.
• SAGE: The HMIS reporting repository where APRs and CAPERs are submitted. Grant recipients must have SAGE access for report submission.
• Single Audit: Organizations expending $750,000 or more in federal awards must complete a Single Audit under 2 CFR 200 Subpart F

Eligibility Verification Checklist

Use this checklist to verify your organization's eligibility before entering the CoC competition or applying as an ESG subrecipient:

• Organization is an eligible entity type (nonprofit, government, PHA, tribal organization)
• Organization operates within the geographic boundary of a registered CoC
• SAM.gov registration is active with current UEI
• e-snaps registration is current (for CoC applicants)
• Organization participates in HMIS (or comparable database for DV providers)
• Organization participates in coordinated entry
• Most recent Single Audit completed and filed (if applicable)
• No unresolved HUD monitoring findings or audit disallowances
• Project component type aligns with CoC's priority needs and NOFO requirements