Late yesterday, the White House directed the Office of Management and Budget (OMB) to order all federal agencies to temporarily block activities associated with the obligation and disbursement of all grants, loans, and other financial assistance. It does not include Social Security or Medicare benefits, nor does it include “assistance provided directly to individuals.”
This temporary pause is scheduled to go into effect at 5:00pm EST today: Tuesday, January 28, and – as far as we know – does not have a specific end date. Many grantees in the field are already reporting an inability to access financial systems that would allow them to draw down funds in advance of the 5 pm ET deadline set by OMB. We understand that legal action is being taken to try and stop this freeze, but the outcome is obviously unknown at this time.
These actions will have a direct impact on people experiencing homelessness, and the programs that serve them.
Details on which specific programs will be impacted and how are still unclear; however, the Alliance will be working to keep you informed throughout this process. Below are some recommendations for immediate next steps that Continuums of Care (CoCs) and recipients of CoC, Emergency Solutions Grants, and other federal grant funding may want to consider today. While these recommendations are specific to HUD Homeless Assistance Grants, they may also be applicable to other federal grants.
- If systems (like eLOCCS and others) become available, submit legitimate grant drawdowns in accordance with the terms of your grant agreements/contracts. Although at least some of the critical systems used by funding recipients to draw down grant funds are currently inaccessible, grantees should continue to prepare to draw down when those systems are re-opened. If your drawdown system is operable, recipients of grant funding should proceed with submitting documentation to draw down allowable funds before 5pm today.
- Take action. The Alliance sent out an ACTION ALERT urging Congress to stand up and speak out TODAY against this latest action by the Trump Administration. We need YOUR voice to tell Congress what the impact would be of even a short-term disruption in obligation and disbursement activity to grants, loans, and other financial assistance in your community.
- Impact analysis and needs assessment. It is still unclear how long this “temporary pause” will last. The Alliance is recommending a needs assessment for the next 30-60 days. CoCs should work with their local providers to begin assessing the impact of the OMB guidance on current program operations. They should start by analyzing existing federal program portfolios that support efforts to prevent and end homelessness (e.g., ESG, CoC, SSVF, RHY, VAWA, VOCA, etc.). An analysis should include:
- How many households, people, and units will be impacted
- Type and quantity of services that that will be impacted
- Rent and leasing payments that will be due during projected time
- Cost to sustain existing staffing levels
- Identify potential short-term funding sources. Reach out to local and state lawmakers as well as philanthropic organizations to explore any supplemental funding streams to support operations during the impacted period.
- Contact landlords. Providers who administer rental assistance should contact landlords and alert them of potential delays in payment.
The Alliance recognizes that the implications of the OMB guidance will also have long-reaching impacts even beyond this temporary pause. Based on the language within the OMB memorandum and the executive actions since January 20, it is evident that efforts aimed at addressing the disproportionate impact of homelessness on some groups, especially people of color and LGBTQ+ individuals, as well as culturally-specific programming, will be most impacted.
CoCs should begin immediately to engage in a community-wide planning process to mitigate harm over the long term. They should also ensure that equity practices within homelessness response systems are embedded in organizational and local processes, absent federal requirements and funding. This includes activities associated with data analysis, human-centered policy and program design, equitable hiring practices, and ensuring continued authentic partnership with people with lived experience of homelessness.
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