The Emergency Food and Shelter National Board Program and Homeless Assistance
Released: 2013-04-10T00:00:00

Summary:
The Emergency Food and Shelter National Board (EFS) Program provides supplemental funding to homeless services providers across the nation. EFS was first authorized by P.L. 100-77, the Stewart B. McKinney-Bruce Vento Homeless Assistance Act (Title III, McKinney-Vento Act), which became law in 1987. Eligible services include the provision of overnight shelter and served meals, assistance to food banks and pantries, one month's rental or mortgage assistance to prevent evictions, and one month's utility payments to prevent service cut-offs.
Since its inception, the program's recipient organizations have provided over 2 billion meals, 241 million nights of shelter, 4.3 million rent and mortgage payments, and 5.9 million utility payments. The program is administered by the EFS National Board, which is chaired by the Federal Emergency Management Agency (FEMA) of the Department of Homeland Security (DHS), and is comprised of representatives from the American Red Cross, Catholic Charities USA, the National Council of Churches, the Salvation Army, the Jewish Federations of North America, and United Way Worldwide. Two of the program's distinguishing features are its focus on local decision-making, and its relatively modest administrative costs.
The program was last authorized in 1994, and has been operating under authority provided by annual appropriations acts. In the past, its funding has generally increased during times of high unemployment and decreased as the unemployment rate declined. For example, in FY2009, the program received an appropriation of $200 million. The American Recovery and Reinvestment Act of 2009 (P.L. 111-5, ARRA) then temporarily increased the EFS program's funding to $300 million for FY2009. In more recent years, the program's funding has declined. The program received an appropriation of $200 million for FY2010, $120 million for FY2011, and $120 million for FY2012. Under the full-year Continuing Resolution (CR, P.L. 113-6) for FY2013, the EFS program is scheduled to receive just under $120 million; however, with sequester amounts not yet confirmed the final amount could be less than that.
Although legislation providing EFS an appropriation of $120 million for FY2012 was signed into law on December 23, 2011, the distribution of the program's funds did not begin until August 15, 2012, the latest award distribution date in the program's history. FY2011 was also a notable year for the program because the EFS National Board changed its distribution formulas, resulting in some large jurisdictions not receiving direct funding for the first time.
The National Board's distribution formula uses unemployment and poverty statistics to determine amounts awarded directly to communities across the nation. After notifying jurisdictions of the amount that they will be receiving, EFS Local Boards, comprised of local affiliates of the organizations represented on the National Board, at least one homeless or previously homeless person, and representatives of local government, are convened. Local Boards advertise the availability of funds, accept applications for funding, and determine which local agencies to fund and how the funds are to be used. The National Board also provides funding to State Set-aside Committees (SSA) which provide funding to jurisdictions with significant needs that may not have qualified under the National Board's formula, or to further supplement funding to jurisdictions that received a direct award. Each state, through direct awards and SSA, receives a minimum of $250,000.
EFS, originally envisioned as a one-time emergency program, has distributed more than $3.9 billion to over 2,500 local jurisdictions and more than 12,000 local service organizations (both non-profit and governmental).
The EFS program's rules and processes emphasize fast response, local decision-making, and local accountability. Some federal programs have emulated its local board approach for decision-making on the use of resources for programs for the homeless. Over the last decade, congressional oversight has occurred through annual appropriations hearings on FEMA in general.
This report examines the administrative history of the program, the evolution of its award process, and the issues that Congress may consider as the EFS program approaches its fourth decade. In particular, the report highlights recent program delays in funding and, in general, how the EFS program and its emphasis on emergency services fit into the context of the federal government's approach to addressing homelessness.

paragraphs: The Emergency Food and Shelter National Board Program (EFS) is administered by the Federal Emergency Management Agency (FEMA), making the program somewhat unique in that its purpose is outside of the agency's traditional focus on preparedness and disaster recovery for individual disaster events. EFS funding is provided to private non-profit organizations and local governments to supplement and expand their efforts to provide shelter, food, and supportive services for homeless individuals, to strengthen efforts to create more effective and innovative local programs, and to conduct minimum rehabilitation of existing mass shelter or mass feeding facilities, but only to the extent necessary to make facilities safe, sanitary, and bring them into compliance with local building codes.
The EFS program began in 1983. For most of its history, the program's funding has generally increased during times of high unemployment and decreased as the unemployment rate declined. However, in recent years, the program's funding has been reduced. In FY2008, the program received an appropriation of $200 million. The American Recovery and Reinvestment Act of 2009 ( P.L. 111-5 , ARRA) temporarily increased the EFS program's funding to $300 million for FY2009. Since then, the program has received an appropriation of $200 million for FY2010, $120 million for FY2012, and $120 million for FY2012.
Congressional interest in the EFS program has increased in recent years, primarily because the program's authorization expired in 1994 and it has been operating under authority provided by appropriations. Also, delays in distributing funds over the last two fiscal years have caused uncertainty among recipient organizations. Given current fiscal conditions, and the lack of program authorization, EFS advocates are concerned that the program's funding, $120 million in FY2012, could be in jeopardy. Some observers also question the program's focus on supporting emergency services, preferring a "more balanced" approach that includes meeting immediate emergency needs for food and shelter, but places added emphasis on supportive services designed to prevent long-term homelessness, such as job counseling and permanent housing. 
This report opens with a legislative history of the EFS program. It then examines the program's current structure and operations, including the composition and responsibilities of the EFS National Board (hereinafter National Board), which is chaired by FEMA, the formula the National Board uses to allocate available funds to eligible local jurisdictions, and the composition and responsibilities of EFS local boards. The report then provides an analysis of the EFS program's relationship to other programs assisting those with acute needs, examines its funding, and congressional debate concerning its efficacy in helping individuals meet emergency needs and transition out of poverty.
subsections: section_title: Legislative Origins
paragraphs: The EFS program's origins can be traced back to the winter of 1980. At that time, Paul Bloom, Chief of the Compliance Division at the Department of Energy (DOE) during the Carter Administration, noted that DOE had accrued about $4 million in interest payments derived from negotiated penalty payment settlements from oil companies. He considered how the interest payments might be used to address unmet energy needs at the local level for families facing daunting heating bills. He contacted representatives from several national social service providers, including The Salvation Army, Catholic Charities USA, the Council of Jewish Federations, and the American Red Cross, and suggested that DOE could release the $4 million to these organizations if they could use the funds to quickly provide energy assistance to those families and individuals with the greatest needs. The funds were subsequently released to these charities.
In 1981, the incoming Reagan Administration announced its intention to recapture these funds. After discussions and negotiations with the non-profit charitable organizations, which reassured the new Administration as to the use of the expended funds, then-DOE Secretary James Edwards announced that plans for a recovery of all the funds were no longer necessary. Eventually, about $1 million of the funds, pending disbursement, were returned.
Representatives of these charities, viewing the ad hoc program as an example of a public-private partnership that should be replicated, approached House Speaker Thomas P. "Tip" O'Neill with a proposal to establish a pilot program, with statutory authority, to assist the homeless. The charities recommended that the program be placed in the Federal Emergency Management Agency (FEMA), primarily as a means to emphasize the emergency nature of the services to be provided. The charities were familiar with FEMA given the agency's disaster response and recovery role, which includes providing assistance to families and individuals. The recommendation to place the pilot program within FEMA also reflected the charities' concerns about the stewardship of the Department of Housing and Urban Development (HUD) at that time. HUD was expected to have an interest in administering the program. 
House Speaker O'Neill indicated an interest in the proposal and, on March 3, 1983, the House approved legislation ( H.R. 1718 , the Temporary Emergency Food Assistance Act of 1983) appropriating $50 million for an emergency food and shelter program. The bill was similar in structure to the charities' proposal, and included the establishment of a National Board chaired by FEMA (FEMA was then an independent agency and is now within the Department of Homeland Security) and comprised of representatives from six non-governmental organizations associated with the provision of homeless services: the American Red Cross; Catholic Charities USA; the National Council of the Churches of Christ; The Salvation Army; the Council of Jewish Federations; and United Way of America. The National Board was charged with the responsibility to determine how to distribute the funds to individual localities. Localities receiving the funds were to form local boards, to be comprised, to the extent practicable, of representatives of the same organizations as the National Board except that the mayor or appropriate head of government replaced FEMA's representative. Local boards were to distribute the funds to homeless services providers on a competitive basis. 
On March 17, 1983, the Senate passed the bill, but with amendments. Like the House version of the bill, the Senate's version would have appropriated $50 million for the program. However, the Senate bill did not include the establishment of a National Board and local boards to distribute the funds. Instead, the Senate bill directed FEMA to distribute the funds, in conjunction with the Director of the Office of Community Services, directly to states using the Community Services Block Grant formula. States would then determine how to distribute the funds among its local jurisdictions.
The final version of the bill was passed by Congress on March 24, 1983, and signed into law by President Reagan later that same day. In a unique agreement, the act ( P.L. 98-8 , the Temporary Emergency Food Assistance Act of 1983) appropriated $50 million for the Senate's version of the Food Distribution and Emergency Shelter program, and $50 million for the House's version of the program.
The enactment of these two programs was largely a reaction by Congress to the recession of 1982, and the growing visibility of homelessness in America as depicted in the media. These programs also reflected the recognition, by Congress, of the burden placed on charitable groups and local governments in addressing these unmet needs.
In early 1983, Congress finally acknowledged that local governments and the non-profit sector could no longer be expected to carry responsibility for sheltering the nation's growing homeless population without substantial assistance from the federal government. Until that time, small amounts of funding for shelter assistance had been made available through a variety of federal agencies, but there had never been any coordinated approach to the problem.
The enactment of two programs reflected competing views concerning which delivery system was best. The Senate's program, like most federal grants, was allocated through the states to ensure that the allocation of funds was subject to rigorous accountability standards. Because the House's program by-passed the states, it was expected to distribute funds more rapidly to local homeless services providers than the Senate's program. However, because the states were not involved, some questioned whether the National Board and local boards were capable of administering the program as well as the states. To address these concerns, the National Board imposed rigorous accountability standards on all program transactions. 
The following year, Congress discontinued the appropriation of funds for the Senate's version of the program. EFS program funds were, and continue to be, used to supplement mass sheltering and feeding facilities, to provide one month's rent or mortgage to prevent evictions and foreclosures, and to provide one month's utility payments to prevent the cut-offs of utility services.
Given the absence of reliable counts of the homeless and the lack of consensus concerning how to measure the need for assistance among the homeless and hungry, the EFS National Board created a formula, using unemployment and poverty statistics, to determine the amount of funding to be awarded directly to communities across the nation. These statistics were thought to be representative of current needs within a community. As will be discussed, modifications to the formula have taken place over time.
The EFS program received statutory authorization in 1987 ( P.L. 100-77 , the Stewart B. McKinney-Bruce Vento Homeless Assistance Act, Title III ─ McKinney-Vento Act). The program was last reauthorized in 1994, and has been operating under authority provided by annual appropriations acts. 
As shown in Figure 1 , the program's funding remained at about $150 million during the early 2000s, and was increased temporarily in FY2009 to $300 million. Since then, the program has received an appropriation of $200 million for FY2010, $120 million for FY2012, and $120 million for FY2012 (see Table A -1 for annual amounts). 
section_title: EFS National Board Membership and Responsibilities
paragraphs: The composition of the EFS National Board (hereafter National Board) has remained constant since its inception in 1983. FEMA continues, by law, to chair the National Board, and the representation from national organizations remains the same: the American Red Cross, Catholic Charities USA, the National Council of Churches, the Salvation Army, the Jewish Federations of North America, and United Way Worldwide. These organizations nominate individuals from their organization to serve on the board.
The appointees nominated to the National Board by organizations have been, except in very rare instances, accepted by FEMA. Since 1983 through September 2012, 49 individuals have served as National Board members. An additional 35 individuals have served as alternate board members. (See Appendix B for a historical listing of National Board members.)
Some social service organizations, such as homeless veterans groups and national food bank organizations (e.g., Second Harvest, now named Feeding America) have expressed interest in serving on the National Board. Because membership is determined by law, the National Board cannot unilaterally expand without legislative change, but it has, upon occasion, sought input from other social services organizations. For example, during the late 1980s, the National Board established an advisory group which included representatives from the Traveler's Aid Society, the Community Action Foundation, the Second Harvest Food Bank network, and the Rural Assistance Coalition. The advisory group's purpose was to provide representation for those groups that have a significant number of local affiliates that receive EFS funding and participate on EFS Local Boards. As will be discussed in the " National Board Membership " section of this report, legislation has not been introduced to expand the National Board's membership.
The National Board is responsible for establishing the formula used to distribute EFS funds, editing and revising EFS program guidelines, overseeing the program's administration and budget, and communicating with EFS Local Boards and agencies, both to receive input about the program and to assess the Local Boards' actions. At its monthly meetings, the National Board also considers requests from Local Boards for waivers of administrative requirements. The National Board has effectively expanded the program's eligibility rules and refined its documentation requirements through its consideration of these waiver requests. The National Board also conducts occasional site visits to Local Boards and Local Recipient Organizations (LROs) to listen to comments and suggestions on how the program can be improved.
The McKinney-Vento Act limited overall EFS program administrative costs to no more than 5% of funding. Subsequent appropriations bills have limited overall EFS administrative costs to no more than 3.5% of funding. The National Board, by its own authority, uses up to 1% of funding for its administrative expenses, and allows Local Boards to use up to 2% of their awards for administrative expenses, and State Set-Aside Committees to use up to 0.5% of their awards for administrative expenses. This is slightly below the administrative rates for other homeless programs.
section_title: EFS Local Board Membership and Responsibilities
paragraphs: EFS Local Boards (hereafter Local Boards) are comprised of affiliates of the National Board, along with the highest ranking government official (usually of a county or city government) whose designee serves in FEMA's place. The law also requires Local Boards to include a homeless or formally homeless representative on the Local Board. For those jurisdictions that are "located within or encompass a Federally recognized Native American reservation, the Local Board must invite a Native American representative to serve on the Local Board." While FEMA is statutorily required to chair the National Board, Local Boards elect their own chair, typically from among its non-profit members. EFS Guidelines encourage Local Boards to include other members as well:
The designated members of the Local Board are encouraged to expand their membership by inviting participation from minority populations and other private nonprofit organizations and governmental organizations. In addition, all geographic areas within the jurisdiction should be represented.
The Local Board's primary responsibilities are to advertise the availability of funds, determine which applicants are to receive funding, monitor the use of funds to ensure that recipients are in compliance with all program requirements, and provide the National Board specified reports of its actions, including required financial documentation from recipients.
The EFS program has provided funding to social service providers for many years, but its funding has not focused on any one social services agency, or group of agencies. Some suggest that the EFS program's local focus, combined with its practice of funding relatively large numbers of social services organizations, leaves it without strong national advocates. National Board member agencies are prominent members of most Local Boards, but significant funding goes to many other non-affiliated groups, such as food banks, Community Action Agencies, church groups, and other independent, locally-based charities. National advocacy groups promoting housing and social services for the homeless and others in need have supported the EFS program, but there is no national association of EFS recipient organizations to lobby on behalf of the program. 
The EFS program is designed to provide Local Boards the primary responsibility for selecting recipients and an important role in monitoring recipient activities. While Local Boards have been lauded for their leadership and collaboration in providing local input and empowering local non-profits as a key part of the decision-making process, there are also potential problems due to the unique arrangement. Local Boards can be either creative or work by rote; they can react to local events and trends, or lock into a routine distribution plan to avoid dissonance; and they can monitor recipient actions closely, or provide more cursory performance reviews. Another potential criticism of Local Boards is that they are subject to the potential for a conflict of interest because Local Boards are comprised of provider agencies that may apply for an award. This concern can be weighed against the expertise that such agencies offer in evaluating applicants and establishing priorities at the local level.
section_title: State Set-Aside Committee Membership and Responsibilities
paragraphs: In 1987, the National Board created a State Set-Aside (SSA) program to provide funding to jurisdictions "which have documented measures of need that are not adequately reflected in unemployment or poverty data, such as areas experiencing drastic economic changes due to a plant closing, and areas with high levels of unemployment or poverty which do not meet the minimum level of unemployment required for a direct award."
SSA Committees include representation from the Governor's Office, National Board affiliates, and any other members the SSA Committee believes is appropriate. Each year, the National Board reserves a portion (generally in the range of 8 to 9%) of its funds for SSA Committees and distributes the funds according to "the ratio of each state's average number of unemployed in non-funded jurisdictions divided by the average number of unemployed in non-funded jurisdictions nationwide." Also, if that state has not received the statutorily required minimum award of $250,000 through the direct award process, that state's SSA Committee may receive an amount to bring that state up to the minimum figure. Conversely, a state with a relatively large direct award could still receive a SSA award depending on the number of unemployed individuals in jurisdictions within that state which did not receive a direct award.
The SSA Committee is directed to fund areas of greatest need in their state. The National Board recommends that SSA Committees consider state and/or local economic data in determining which jurisdictions receive funding, but the National Board does not mandate any particular formula to enable SSA Committees to meet needs that are particular to that state or locality. The National Board reviews the SSA Committee's funding decisions prior to the award of funds, and requires SSA Committees to submit a waiver request if they wish to provide additional funding to qualifying jurisdictions that have a direct award.
The SSA program expands the EFS program's geographic coverage. For example, as shown in Figure 2 , in FY2010, 2,021 (77%) of jurisdictions receiving EFS program funds were awarded funds through the National Board's formula, and 609 (23%) were awarded funds by SSAs. These proportions are representative of most years.
section_title: Timing of Award Announcements
paragraphs: In years when the appropriations process is completed without a continuing resolution, the National Board has typically announced its awards, and notified the SSA Committees of the amount of funds available to them, in late November. In FY2011, FEMA's appropriations were not passed and signed into law until April 15, 2011, and EFS award announcements were made on July 15, 2011, then the latest date for award announcements in the program's history. FEMA attributed the delay to language in the Continuing Resolution (CR) for that year which FEMA interpreted to mean that it could not fund programs, such as the EFS program, that award most of its available funding at the beginning of the fiscal year. Section 109 of the CR ( P.L. 111-242 ) stated:
Notwithstanding any other provision of this Act, except section 106, for those programs that would otherwise have high initial rates of operation or complete distribution of appropriations at the beginning of fiscal year 2011 because of distributions of funding to States, foreign countries, grantees, or others, such high initial rates of operation or complete distribution shall not be made, and no grants shall be awarded for such programs funded by this Act that would impinge on final funding prerogatives.
In the past, FEMA had sought, and was allotted, all program funds under previous CRs so that funding could be provided to social service providers during the winter months. In FY2012, EFS program funding was delayed, once again, due to language in the five CRs enacted for the FY2012 budget prohibiting the distribution of funds that would impinge on final funding prerogatives. The National Board announced its FY2012 awards on August 15, 2012, more than seven months after the final appropriations act for FY2102 ( P.L. 112-74 , the Consolidated Appropriations Act, 2012) was signed into law, and more than 10 months after the first CR for FY2012 ( P.L. 112-33 , the Continuing Appropriations Act, 2012) was enacted.
subsections: section_title: Special Awards
paragraphs: As it approaches the end of each program year, the National Board reviews any funds that remain. These are funds generated by interest payments prior to fund distribution, from some jurisdictions that do not use all of their funding, or from funds that are refunded to the National Board if they were spent improperly. These funds are often rolled over into the following year's budget under authority provided by the McKinney-Vento Act. However, the National Board has also used these funds to make special awards. For example, in the past, the National Board has provided funding to support veterans "stand downs" where "homeless veterans are brought together in a single location for one to three days and are provided access to the community resources needed to begin addressing their individual problems and rebuilding their lives."
FEMA and the EFS National Board have been careful to note the difference between homelessness addressed by the EFS program and homelessness that occurs as the result of natural disasters, and to differentiate between funds appropriated for the EFS program and the large sums appropriated for the Disaster Relief Fund (DRF) that provides resources for the Stafford Act disaster relief programs. However, the EFS National Board has also been cognizant of the needs of social service organizations after large scale disaster events and has occasionally sent supplementary awards to EFS Local Boards in those areas. This is of some importance since FEMA's handling of those people already homeless at the time of a disaster has been a recurring policy question. 
section_title: The Qualifying Formula
paragraphs: The National Board requires jurisdictions to meet a minimum number of individuals unemployed threshold to be considered for funding. The current threshold is 300 unemployed individuals. Once that threshold is met, jurisdictions must also meet an unemployment rate threshold and/or a poverty rate threshold to qualify for funding. The National Board "adopted this combined approach in order to more effectively target funds for high-need areas and to allocate these funds rapidly and fairly."
For most of the program's history, the National Board established a poverty threshold that was slightly below the national poverty rate and two unemployment rate thresholds ─ one for larger, presumably urban/suburban, jurisdictions (cities or counties of 50,000 or more) and another for smaller, presumably rural, jurisdictions (cities or counties of fewer than 50,000). The unemployment rate thresholds varied from year to year, adjusting to changes in the national unemployment rate. The threshold for larger jurisdictions was usually set at 1% below the national average unemployment rate. The threshold for smaller jurisdictions was usually set at 1% above the national average unemployment rate. For example, for FY2008, using the previous year's average national unemployment rate of 4.5%, larger jurisdictions qualified with an unemployment rate of 3.5% or above and smaller jurisdictions qualified with an unemployment rate of 5.5% or above.
The National Board purposely made it easier for larger jurisdictions (whether cities or counties) to qualify on unemployment to ensure that available funds were provided to jurisdictions most likely to have large homeless populations and significant hunger needs. It was believed that larger jurisdictions provide more social services, have larger populations in need, and tend to attract people in need of such services.
As shown in Figure 3 , the National Board dropped the dual unemployment thresholds for distributions made in FY2011, opting to set a single unemployment threshold of 2.0% over the national average unemployment rate for all jurisdictions (11.5%). Because the program's funding declined in FY2011, and the unemployment formula changed, some large jurisdictions did not receive a direct award for the first time in many years. 
The National Board continued the use of a single unemployment threshold in FY2012 (11.4%). The National Board has not indicated in its publications the reason for moving to a single unemployment threshold. One possibility is that the change may represent the National Board's effort to treat all jurisdictions more equally given that available funding has declined.
Once a jurisdiction meets one of these thresholds, it is eligible to receive a direct award. The direct award amount is determined by first dividing the total amount of funding made available for direct awards by the total number of unemployed in all eligible jurisdictions. This per capita funding rate is then multiplied by the number of unemployed in each qualifying jurisdiction to determine the amount of the direct award. Because the formula remained fairly static until FY2011, the National Board had provided fairly consistent funding amounts to qualify jurisdictions. The formula change in FY2011, coupled with a reduction in available funding, created a relatively significant shift in the distribution of funds among jurisdictions.
SSA Committees typically receive less funding than the amount awarded to their state through the direct award process. As a result, SSA awards, typically, are smaller, on a per capita unemployed basis, than direct awards. For example, as shown in Figure 4 , the per capita unemployed amounts for FY2010 were: $14.84 per unemployed individual in jurisdictions receiving direct funding through the National Board's formula, and $10.31 per unemployed individual in jurisdictions selected by SSA Committees. For FY2010, the directly funded jurisdictions received approximately 92% of available funds, and SSA jurisdictions received the remaining 8%.
Until the changes made to the formula for FY2011, Congress had not raised specific questions concerning the National Board's funding formula in recent years. However, Congress has critiqued various formulas used by HUD to distribute funding to assist the homeless and encouraged all departments and agencies to search for improved methods to distribute funds to assist the homeless. For example, P.L. 111-22 , the Homeless Emergency Assistance and Rapid Transition to Housing (HEARTH) Act, directed HUD to "create a new formula for determining needs in the distribution of homeless assistance grants."
section_title: Congressional Issues
subsections: section_title: FEMA's Administration
paragraphs: As mentioned previously, the National Board is responsible for overseeing SSA Committees and Local Boards. FEMA provides oversight of the National Board, and by extension, SSA Committees and Local Boards. In addition, in accordance with authorizing legislation, the National Board's accounts are "audited annually in accordance with generally accepted auditing standards by independent certified public accountants or independent licensed public accountants certified or licensed by a regulatory authority of a State or other political subdivision of the United States." The EFS program has also been audited, both at the national and local level, by the DHS/FEMA Office of Inspector General. Since its inception, the EFS program has also been the subject, or a part of, more than 15 Government Accountability Office (GAO) reports. 
The recent GAO report on overlap and fragmentation in homeless services programs concentrated its attention on HUD, the Department of Health and Human Services (HHS), the Department of Labor (DOL) and the Department of Veterans Affairs (VA). Its only comments regarding FEMA's management of the program were that the collected numbers of meals and nights of shelter did not definitively note the number of actual homeless people assisted. In addition, the table used in the report noted that the program did not appear to have performance metrics or targets for the level of performance. DHS/FEMA's response to the report did not address those issues but reiterated the number of meals and nights of shelter and other assistance provided.
Some organizations, including the DHS Office of Inspector General, have questioned FEMA's commitment to EFS program oversight. A 2009 report by the DHS Office of Inspector General noted:
Staff within the Emergency Food and Shelter Program declined from six in 1997 to one in 2008. According to FEMA program officials, this decline led to a significant decrease in financial and program monitoring. Having one staff member responsible for both monitoring activities reduces FEMA's ability to ensure the appropriate use of grant funds.
FEMA explained that staff overseeing the EFS program were reassigned to other FEMA priorities, including disaster assistance programs. While no staff levels are currently listed for the program at least one FEMA staff member appears to be assigned to the program 
EFS program advocates argue that FEMA was able to maintain the EFS program's staff level in the past while also providing disaster assistance a high priority. In their view, the only material change in circumstances was in FEMA's commitment to the program. Advocates argue that reducing FEMA staff has had consequences. For example, they assert that the EFS program was more likely to engage in cooperative endeavors with other federal programs providing assistance to the homeless when the EFS program had additional support staff. They cite FEMA's Food Donation program, where Local Boards identified local organizations that could receive food items from Department of Defense (DOD) commissaries that could no longer be sold or returned to the vendor, as an example of a cooperative endeavor that happens less frequently now that FEMA's EFS program staffing level has been reduced. The DOD commissaries were matched with one vendor that could be cleared for entrance to the base and pick up food items and distribute them in the community. In 1997, this EFS-related program accounted for more than $3 million in donated food items from 65 DOD commissaries. While such relationships may be ongoing, there is no information available on the current status of this initiative.
A fundamental question regarding the EFS program is whether it should remain at FEMA or move to a different department or agency. Although the EFS program has been administered by FEMA since its inception in 1983, each succeeding administration, with the exception of the Obama Administration, has offered legislative proposals, or recommended in its budget submission, to move the program to the Department of Housing and Urban Development (HUD) to better align it with the homeless assistance programs within that department. Congress has chosen to keep the program at FEMA.
Advocates of moving the EFS program to HUD, or to another federal department or agency, could argue that the move is warranted given that FEMA's interest in the program has, arguably, waned in recent years, as evidenced by FEMA's decision to reduce the number of EFS program support staff and FEMA's apparent lack of urgency or attention provided to the distribution of EFS program funds in FY2011 and FY2012. These significant delays in distributing funds are in contravention of the McKinney-Vento Homeless Assistance Act which requires:
Not later than 30 days following the date on which appropriations become available to carry out this part, the Director shall award a grant for the full amount that the Congress appropriates for the program under this part to the National Board for the purpose of providing emergency food and shelter to needy individuals through private nonprofit organizations and local governments in accordance with section 11343 of this title.
It would appear that FEMA has not been able to meet this requirement in the last two fiscal years. It can be argued that the rules of the Continuing Resolution during FY2011 prevented or at least hindered FEMA in administering this section. However, FEMA's nearly nine month gap from the President signing of the DHS appropriation in December of 2011 to the eventual announcement of the distribution of funds in August of 2012 has not been explained. Similarly, the EFS National Board, which FEMA chairs, is directed in the McKinney-Vento Act to act swiftly.
Any amount made available by appropriation Acts under this subchapter shall be disbursed by the National Board before the expiration of the 3-month period beginning on the date on which such amount becomes available.
All of this would appear to indicate a change in administration might be in order. On the other hand, moving the EFS program to HUD, or any other federal department or agency, could lead to several unanticipated consequences. For example, would the potential benefits of such a move (e.g., the enhanced potential to reduce program duplication and/or achieve administrative economies of scale by sharing program staff with programs of a similar nature) exceed the potential costs (e.g., increasing the potential for the program to lose its identity as a primary provider of emergency services and its focus on local decision-making).
In the past, most EFS program participants argued "if it ain't broke, don't fix it" in response to the question of whether to move the program from FEMA to another federal agency. To date, Congress has not supported proposals to move the program to another agency, primarily because the program has traditionally distributed funds relatively quickly, has relatively low administrative costs, and, has been relatively popular with provider groups.
section_title: Program Focus
paragraphs: The term "continuum of care" within the emergency services community refers to the strategy of addressing the continuum of needs of homeless persons: prevention of long-term homelessness, emergency shelter, transitional housing, permanent housing, and supportive services (such as job counseling and medical care) provided at all stages of housing assistance. A criticism of the EFS program is that its focus on providing funding for emergency services, as opposed to transitional or permanent solutions to homelessness, represents a "band-aid" approach to addressing problems, rather than focusing on long-term solutions to homelessness. Although other programs attempt to address long-term solutions to homelessness, some prefer that all federal programs, including the EFS program, focus on transitional or permanent solutions to homelessness. Others disagree. For example, some have argued that meeting immediate needs of homeless individuals is the fundamental basis for any progress. As one commentator stated shortly after the enactment of the McKinney-Vento Act, the provision of emergency assistance is necessary and federal assistance for emergency assistance is needed:
There is absolutely no reason why public shelters should be horrible places, horribly run. Nobody thinks shelters are an ideal answer. But the lesson of the last decade is that they aren't mere emergency measures either. The time has come to think seriously about how best to maintain them.
A fundamental question in considering the EFS program is whether assisting communities to meet emergency needs is an appropriate goal for a federal homeless program. The supplemental nature of the program reflects the interest of the legislation in establishing a partnership in which federal funding helps to build capacity and reach of local emergency programs. However, the use of resources on emergency services also diminishes funds that can be directed at long-term solutions for homeless families and individuals. 
A change in the focus of the program to finding long-term solutions to homelessness could further promote ongoing collaborative efforts such as the Continuum of Care in many communities. But if the EFS program changes its focus it would also be leaving behind a program that reached out more broadly geographically and, because of that breadth, also to many smaller recipient organizations that other programs cannot reach. These types of recipient organizations, that provide basic emergency assistance, may not qualify for grant assistance under more sophisticated programs and systems devoted to long-term efforts.
section_title: National Board Membership
paragraphs: As mentioned previously, changing the National Board's membership requires legislative action. Some groups argue that expanding the National Board's membership would promote greater inclusiveness and improve the representation of local recipient organizations. For example, Feeding America has sought membership on the National Board, arguing that many of its affiliates receive EFS program funds at the local level and those affiliates, in turn, are in constant contact with the many organizations that they serve with food donations. Also, as Feeding America argued in a letter advocating its membership: 
We also could help provide additional data to the Board through our Research Department, which does ongoing research on hunger across the country as well as the Hunger Study, the most comprehensive look at hunger in America
Similarly, some have argued for greater representation on the National Board for organizations providing assistance to homeless veterans, arguing that veterans are overrepresented, on a per capita basis, among the homeless population. 
Arguments for not increasing the National Board's membership include: the current membership size provides for expeditious handling of EFS program administration, the EFS program formula for distributing funds is sufficiently broad to ensure that all recipient population groups are included, and, depending on how the new board members are selected, adding new members could present Congress with the task of choosing among prospective member organizations. 
section_title: EFS Administrative Budget
paragraphs: As mentioned previously, the EFS program is currently operating under authority provided by annual appropriations acts and those acts have limited the program's administrative budget to no more than 3.5% of available funding, compared to no more than 5% under the McKinney-Vento Act. EFS program advocates often note in their advocacy for the program that the EFS program has relatively low administrative costs. However, limiting the program's administrative budget to 3.5% of funding has consequences. For example, the EFS program has a substantial database that contains information on all participating agencies, as well as data on the use of funds (e.g. for food banks, served food, sheltering, rental assistance, etc.) in over 2,500 communities in every state and territory since the program began making awards. While various think tanks and government researchers have used the EFS database for various purposes, the EFS program itself has never conducted its own in-depth research using this database, primarily due to its limited administrative budget. Also, FEMA has not had, until recently, an Office of Policy Development and Research to provide an analysis of the EFS program's accumulated data and to make recommendations for the improvement of its programs. As one researcher noted at a congressional hearing, the emphasis on local decision-making under the EFS program may not result in preventing homelessness if the local leadership does not have the information necessary to "measure whether or not family homelessness has been reduced."
In the absence of increased funding, either from Congress or another source, an increase in the amount available for administrative purposes could, conceivably, lead to a reduction in program services. On the other hand, increasing funds for administration could also provide the National Board with the resources necessary to seek and evaluate additional data from Local Boards. Also, among Local Boards, only large jurisdictions receive enough administrative funding to hire staff devoted solely to the program. For example, the Columbus, Ohio area received an $820,000 direct award for FY2010. Given the 2% administrative budget limit for Local Boards, Columbus could have used up to $16,400 of its award for administrative expenses, not enough to hire a full-time staff member to oversee the program. If additional administrative support was available, Local Boards could, conceivably, be better positioned to provide more detailed information on program spending, how that spending relates to other social service programs, and provide additional oversight of spending and administrative practices as well.
section_title: Conclusion
paragraphs: Given current fiscal conditions, recent reductions in the program's funding, the lack of a national association of EFS program recipients to advocate for the program, and the lack of consensus concerning the role of emergency services in addressing the needs of the homeless, the EFS program's future appears to be in question. For example, some argue that the Obama Administration's recommendation to reduce funding for the EFS program reflects growing support for the argument that emergency assistance should be funded locally and federal assistance should be concentrated on long-term solutions. Those who reach this conclusion note that under ARRA, the EFS program received an additional $100 million in temporary funding in 2009, compared to $1.5 billion provided to HUD's Homelessness Prevention and Rapid Re-Housing Program (HPRP), which focuses on intervention, not emergency services.
Others argue that emergency shelter assistance is still a necessary first step in addressing the problems of people in need of immediate shelter.
A majority of homeless people counted were in emergency shelters or transitional housing programs, but nearly 4 in 10 were unsheltered, living on the streets, or in cars, abandoned buildings, or other places not intended for human habitation. The unsheltered population increased by 2% from 239,759 in 2009 to 243,701 in 2011, the only subpopulation to increase.
Therefore, the choice may not be so stark. As previous initiatives suggest, one approach to homelessness may be to consider it as a continuum in which emergency services lead to transitional services and finally to permanent housing. But, the question remains whether the EFS program, the original, national homeless assistance program, will continue to be viewed as an important component within an overall federal strategy to address homelessness, and within its own department.
Appendix A. EFS Program Funding
Appendix B. EFS National Board Members