24 CFR §576.400

ESG Coordination & CoC Certification Letters

If your agency receives — or is applying for — Emergency Solutions Grant (ESG) funding anywhere in our 37 counties, HUD requires you to coordinate with the Alabama Balance of State CoC (AL-507). Here's what that means, and how to request a certification letter from ARCH documenting it.

Note: ESG is a separate HUD program from the CoC Program Competition (the annual NOFO covered on our Program Funding page). This page is only about ESG/ESG-CV coordination and certification letters — see Program Funding for CoC Program Competition dates and materials.

In a hurry? If your ESG funder is requesting a letter certifying your HMIS use and CoC coordination, skip to Request a Certification Letter below.

What HUD Requires

ESG & CoC coordination, in plain language

Under 24 CFR §576.400, ESG recipients and subrecipients must coordinate with the Continuum of Care serving their area. Here's what that covers.

Consultation with the CoC — §576.400(a)

The recipient must consult with AL-507 on how to allocate ESG funds each program year, on developing performance standards and evaluating outcomes for ESG-assisted projects, and on funding, policies, and procedures for HMIS administration.

Coordination with Other Homeless Services — §576.400(b)

ESG-funded activities must be coordinated and integrated, to the maximum extent practicable, with other homeless-targeted programs in the CoC's area — building one strategic, community-wide system rather than parallel ones.

Coordinated Entry — §576.400(d)

Every ESG-funded program or project in AL-507's area must use the CoC's centralized/coordinated assessment system, with screening, assessment, and referral consistent with CoC written standards. (Victim service providers may opt out of the shared system.)

HMIS Participation — §576.400(f)

Data on everyone served and every activity funded under ESG must be entered into AL-507's HMIS (or, for victim service/legal service providers, a comparable database) — never entered directly into or shared with HMIS from a comparable database.

Source: 24 CFR §576.400 (Area-Wide Systems Coordination), §576.107 (HMIS), and 24 CFR §578.7(a)(8) (CoC Coordinated Entry Responsibilities). Full text: CoC & ESG Regulatory Coordination Requirements (PDF).

24 CFR §578.7

It's not one-directional — HUD requires the CoC to coordinate too

Coordination runs both ways. Just as ESG recipients must coordinate with AL-507, HUD's CoC Program regulations require ARCH, as the Continuum of Care, to consult with and report on ESG recipients in its area. This is the regulatory basis for the certification letters ARCH issues.

Coordinated Assessment — §578.7(a)(8)

In consultation with ESG recipients in its area, the CoC must establish and operate a centralized or coordinated assessment system — including specific protections for survivors of domestic violence, dating violence, sexual assault, and stalking.

Written Standards — §578.7(a)(9)

In consultation with ESG recipients, the CoC must establish and consistently follow written standards for providing assistance — eligibility, prioritization, and rent-share policies among them.

Fund Allocation Consultation — §578.7(c)(5)

The CoC must consult with State and local government ESG recipients in its area on the plan for allocating ESG program funds.

Performance Evaluation & HUD Reporting — §578.7(a)(7), (c)(5)

The CoC must evaluate outcomes of projects funded under both ESG and the CoC Program and report to HUD, including reporting on and evaluating the performance of ESG recipients and subrecipients.

Source: 24 CFR §578.7(a)(7), (a)(8), (a)(9), and (c)(5) (Responsibilities of the Continuum of Care). Full text: CoC & ESG Regulatory Coordination Requirements (PDF).

AL-507 Expectations

What ARCH asks of ESG-funded agencies

  • Maintain active membership in AL-507
  • Participate in Coordinated Entry activities and referrals
  • Participate in HMIS or a comparable database, as applicable
  • Attend CoC meetings, trainings, and planning activities
  • Participate in Point-in-Time (PIT) & Housing Inventory Count (HIC) activities, as requested
  • Respond to CoC requests for planning, reporting, and performance data
  • Coordinate services with other homeless assistance providers for an effective community-wide response
Certification Letter

Need proof of CoC coordination for your ESG application?

Many ESG and ESG-CV funders — including the State of Alabama — require applicants to submit a letter from the Continuum of Care certifying that the project uses HMIS, participates in Coordinated Entry, and consults with the CoC as required under 24 CFR §576.400.

ARCH issues these certification letters for agencies operating within AL-507's 37 counties. To request one, email arch@archconnection.org with the details below — allow a few business days for turnaround, especially close to funder deadlines.

Request a Certification Letter

Include in your request:

AgencyLegal agency name and county/ies served
FunderWhich ESG/ESG-CV funder is requesting the letter, and the deadline
HMISCurrent HMIS or comparable-database participation status
Coordinated EntryCurrent CE participation status
ContactAuthorized representative's name, title, phone, and email

Have a technical assistance question first?

e-snaps, match requirements, HMIS setup, Coordinated Entry — ask before you apply.

arch@archconnection.org