On August 4, 2026, the U.S. Department of Education (ED) issued a Dear Colleague Letter clarifying that local educational agencies (LEAs) may use McKinney-Vento Education for Homeless Children and Youth (EHCY) funds for short-term, temporary emergency housing — including motel and hotel stays — on a case-by-case basis, when reasonable and necessary to facilitate school attendance and as a last resort when other funding sources are not readily available. Alongside the letter, ED reissued the full EHCY non-regulatory guidance, incorporating this use of funds. This is the first update to that guidance since 2018.

During the pandemic, short-term emergency housing was reported by many school district homeless liaisons to be one of the most impactful uses of funds — improving attendance, keeping schools connected to highly mobile students, and opening doors to housing programs that families and youth otherwise could not access. ED’s guidance now extends this flexibility to the regular EHCY program.

Below are resources to help state and local educational agencies make the most of this new flexibility – while establishing strong internal controls – to improve school attendance, stability, and support for students experiencing homelessness.

Considerations for State Educational Agencies

Download the PDF: “Considerations for State Educational Agencies”

State educational agencies (SEAs) play a key role in implementation. LEAs will look to their SEAs for direction on process, compliance, and documentation. This resource explains why short-term emergency housing, with strong internal controls, can be a strategic use of EHCY funds to improve educational outcomes for students experiencing homelessness, and offers considerations to help SEAs guide subgrantees toward strong, fiscally responsible implementation.

Short-Term, Temporary Emergency Housing as a School Attendance and Retention Strategy

• Short-term emergency housing can keep students in school. Families and youth who do not know where they will sleep at night struggle to attend school regularly. Under ARP-HCY, LEAs reported that the ability to quickly place a family in a motel stabilized attendance, kept the school in contact with the family, and made it possible to route transportation to a known location while longer-term options were pursued. Keeping the family within the school’s attendance area also avoids the added cost and disruption of a move far from a student’s school of origin.
• In rural and suburban communities, short-term emergency housing may be the only option. Many communities have no family or youth shelter at all; communities that do have shelters often have waiting lists. When no shelter exists, a short motel stay is frequently the only way to keep a family within the school’s attendance area. The alternative may be a move far from the child’s school, disrupting education, creating transportation challenges, and increasing the likelihood of absences and disengagement.
• Short-term emergency housing builds relationships while keeping children and youth safe. A safe, known place to sleep allows school staff to stay connected with families, assess other needs interfering with attendance, and protect children from unsafe situations. Liaisons consistently report that being able to respond to a family’s most urgent need is what re-engages families who have lost trust in educational systems.
• Short-term emergency housing can bridge to longer-term housing. Under the U.S. Department of Housing and Urban Development (HUD) definition of homelessness, families who self-pay for a motel are not considered homeless and cannot access HUD homeless assistance. However, families whose motel room is paid by a government source or charity are eligible for assistance. Therefore, when an LEA pays for a motel stay (directly or through a third party) it can open the door to housing navigation, case management, and longer-term housing programs the family could not otherwise access. Even when HUD homeless assistance is not available, a motel stay can provide more time to find privately-funded programs and other more stable options.
• Using EHCY subgrant funds for short-term emergency housing can help LEAs leverage additional community resources to support students and families. During the pandemic, LEAs that used ARP-HCY funds for short-term, emergency housing were able to leverage those funds to bring in additional support from private and public sources, including food, clothing, and afterschool support. 

State Considerations for Guiding LEAs

1.  Send ED’s guidance directly to superintendents, chief finance officers, fiscal teams, and homeless liaisons. Sharing guidance with the entire LEA implementation team in a single message directly from the SEA ensures that everyone receives the same information about allowability, promotes collaboration, and facilitates smooth implementation. During ARP-HCY, many liaisons reported that school administrators or school business officers were reluctant to allow federally-approved uses of funds. Clear communication from SEAs helps liaisons make the case to stakeholders in their LEA and prevents fear of noncompliance from blocking an important allowable use. SHC’s LEA Considerations for Short-Term Emergency Housing offers practical strategies learned from LEAs during ARP-HCY.

2. Determine appropriate length of stay in collaboration with LEAs. ED does not set a universal maximum length of stay. Instead, the SEA, in coordination and collaboration with its LEAs, must determine the appropriate length of time. During ARP-HCY, rigid interpretations about the number of days a family could stay in short-term emergency housing left families without time to even receive a return phone call from a homeless services program or housing provider, much less secure placement. Schools didn’t have enough time to re-route buses or arrange other transportation before families were forced to move again. SEAs should make length of stay determinations with LEAs rather than for them, and anchor them to school attendance — for example, ensuring a student can complete a week of school before a housing change. The appropriate length of stay should be grounded in documented, case-by-case determinations rather than an arbitrary cap. SEAs should have procedures in place to allow exceptions when there are extenuating circumstances

3. Build short-term emergency housing into the subgrant application and review process. Confirm that the EHCY subgrant application, instructions, and budget categories accommodate short-term emergency housing, and that mid-year budget amendments can be processed quickly. Equally important, make sure that everyone involved in a subgrant budget — program staff, fiscal reviewers, and grants management staff — knows this is an allowable use and how to approve a budget that includes it. During ARP-HCY, LEAs reported that “red tape,” including delays getting uses of funds approved, was the single biggest challenge they faced in using their funds. A brief internal walkthrough with SEA staff before applications open can prevent an allowable request from being denied at the review stage.

4.  Help LEAs budget realistically in their subgrant applications or budget amendments. Encourage applicants to estimate need (expected referrals per month, average nights per stay, average local motel rates, seasonal rate increases) and establish criteria for who receives emergency stays. Estimates also should account for circumstances that may affect cost; for example, large families may need more than one room.

ED’s guidance directs that cost determinations consider the relative impact of the expenditure given the size of the grant and the number of students who would benefit, particularly in light of the LEA’s needs assessment. This points SEAs and LEAs back to the needs assessment already in the subgrant process, rather than to an arbitrary percentage, in deciding how much of a subgrant goes to emergency housing.

Rather than setting a cap on the share of funds that can go to short-term emergency housing, help LEAs ground the decision in data. What are the local rates of chronic absenteeism among students experiencing homelessness? What patterns of mobility is the LEA seeing? How does short-term emergency housing support the LEA’s other McKinney-Vento priorities? Grounding the budget in these questions may help ensure more effective use of funds than setting a fixed percentage, which may not fit every community’s circumstances.

5.  Point LEAs toward established methods for effective cost-management and administration. SEAs can share sample agreements and templates (including those developed by LEAs in their state), answer questions about allowability, offer technical assistance, or connect LEAs with peers who have working arrangements. Approaches include:

• Contracting or entering into an MOU with a community-based organization or booking service that already holds motel contracts. During ARP-HCY, these arrangements enabled next-day placement, removed the credit-card barrier for families, and protected staff capacity by shifting responsibility for making reservations and invoicing off school staff. ED’s own evaluation found that community-based partnerships were essential to expanding LEAs’ capacity to use ARP-HCY funds, and that roughly one-fourth of LEAs contracted with community-based organizations for services including transportation and wraparound supports.
• Negotiating a rate agreement directly with a local motel or hotel. A short preferred-rate agreement can lock in a nightly rate, substitute a photo ID for a guest credit card at check-in, set up direct billing, and cap the LEA’s responsibility at the nightly rate. (See Resources below.)
• Working in a consortium or county-level arrangement. Smaller and rural LEAs that don’t have the capacity to support their own program can join a shared county or regional program and pay by invoice only for the stays they use.

Whichever pathway an LEA chooses, standard procurement and purchase-order timelines can create barriers for a family that has nowhere to sleep. Encourage LEAs to set up an expedited payment pathway that includes who can authorize a motel stay, how fast, and how it is paid.

6.  Equip LEAs to answer questions about liability, incidentals, and unaccompanied youth. These questions frequently prevent programs from getting started. SEAs can share sample language or point LEAs to their peers who have resolved these questions.

• Liability and damages. Agreements can provide that the LEA is responsible only for the nightly room rate, with any damages handled directly between the guest and the property. See sample indemnification language in this sample rate agreement.
• Incidental deposits and check-in. Decide in advance how any incidental deposit is covered so families aren’t asked for credit cards they may not have. A rate agreement or MOU can waive the deposit or shift it to the LEA or third party, and substitute a photo ID at check-in.
• Unaccompanied youth under 18. Clarify whether state and local policies allow motel placements for minors, under what circumstances, and what a motel requires for a reservation in a minor’s name. These youth often face the most extreme lack of shelter options.

7.  Pair the flexibility with monitoring and technical assistance. Review emergency-stay documentation as part of regular subgrant monitoring rather than creating separate pre-approval hurdles for each stay, which defeats the emergency purpose. Share the National Center for Homeless Education (NCHE) allowable cost decision tool, answer subgrantee questions quickly, and share answers publicly so all LEAs benefit. Consider hosting peer-learning opportunities where LEAs with established programs or prior experience can share rate agreements, MOUs, and lessons learned.

8.  Coordinate at the state level. Connect the EHCY program with state housing agencies, Continuums of Care, and statewide nonprofit partners so that short-term emergency housing links families to housing navigation and longer-term programs. Where state administrative processes (budget amendments, vendor approvals, gift card or lodging policies) create barriers, evaluate whether they can be modified — ED made the same request of states during ARP-HCY.

Considerations for Local Educational Agencies

Download the PDF: “Considerations for Local Educational Agencies”

Writing Short-Term, Temporary Emergency Housing Into Your EHCY Subgrant

• Contact your state coordinator. Reach out to your State Coordinator to learn how your SEA is approaching this use of funds and what documentation it expects. Because ED’s guidance is newly released, your state coordinator may not yet have state-level guidance to share. Reaching out proactively lets them know of your interest and can inform how the state develops any parameters or guidance.
• Name short-term emergency housing in a budget amendment to your existing grant, and/or in your application and budget narrative for a new grant. Describe short-term emergency housing as extraordinary or emergency assistance to enable attendance and full participation in school, which is an authorized use of EHCY funds. 42 U.S.C. § 11433(d)(16). Explain your criteria and documentation process.
• Estimate the need. Need will likely exceed funds; therefore, develop a process for prioritizing which situations receive assistance and determining what share of your subgrant to allocate for this purpose. ED’s guidance directs that cost determinations consider the relative impact of the expenditure given the size of the grant and the number of students who would benefit, particularly in light of your needs assessment — so use the needs assessment you already conduct as the basis for that decision, and be prepared to explain it.

Key Considerations for Implementation

1.  Third-party partners. The single best overall strategy is to enter a MOU or contract with a community-based organization or booking service (such as Safe Stays by ReloShare) that already holds motel contracts. During ARP-HCY, third-party arrangements enabled next-day placement, removed credit card barriers for families, and linked families to housing navigation and case management, all while shifting the job of invoicing and making reservations off school staff. In essence, third-party arrangements solve most of the issues that are likely to be raised, including many of the considerations listed below. Smaller LEAs can ask their county office or neighboring districts about joining a shared program and paying via invoice. See the archived webinar in Resources below for one county’s model. 

2.  Rates and rate agreements. Ask local motels/hotels about a negotiated rate agreement establishing a preferred nightly rate. Agreements can also address check-in requirements (e.g., photo ID rather than a guest credit card), direct billing, and no-show policies. Without a flat rate, budget for seasonal spikes. See Resources below.

3.  Incidental deposits and liability. Decide in advance how incidental deposits will be covered so families are not asked for a credit card they may not have. Include language in agreements limiting the LEA’s responsibility to the nightly rate, with any room damages handled between the guest and the property, and consult your business office on indemnification terms.

4.  Length of stay. ED’s guidance does not set a universal maximum. Instead, the SEA, in coordination and collaboration with its LEAs, must determine the appropriate length of time. “Short-term” should be anchored in school attendance and determined case-by-case — for example, ensuring a student can complete a week of school before a housing change. Build in a process for extensions when a family is close to a shelter bed or housing placement, or may be in physical danger (e.g., forced into a car or a campground in freezing weather), with documentation of the continued barrier and ongoing housing referrals. Experience shows it can take several days just to receive a return call from a housing provider. If your state has set a length of stay limit that does not allow for extensions, document the cases where it was not sufficient to resolve the barrier and share them with your state coordinator.

5.  Process and procedures. Emergencies do not wait for purchase orders. Work with your business office and appropriate LEA leadership — and, depending on your district, federal programs, purchasing, transportation, and student services — to establish streamlined procedures before an emergency occurs. As noted above, a third-party contract is often the best way to navigate logistical, capacity, and other issues. If that is not possible, streamlined procedures should include who can authorize a stay, how quickly, and how it will be paid.

6. Documentation. For each stay in short-term emergency housing, briefly document the student’s circumstances, how the stay removes an immediate barrier to attendance, the coordination steps taken to find other resources first (names/dates of housing provider contacts are enough), and the expected duration with a review date. ED’s guidance requires that case-by-case decisions be adequately documented (2 C.F.R. § 200.302(b)(3)); a brief entry covering these elements meets that expectation.

7.  Unaccompanied homeless youth. Youth on their own often face the most extreme lack of shelter options. Find out if your state and local policies allow motel placements for minors, under what circumstances, and what a motel will require for a reservation for a student under 18. Address these questions in your MOUs.

8.  Keep families close to school. Place families in short-term emergency housing near the student’s school whenever possible to make transportation easier to arrange and avoid the added cost of a move far from the school of origin. ED’s guidance requires LEAs to work to connect the family or unaccompanied youth to sustainable housing supports through appropriate community partners (42 U.S.C. § 11432(g)(5)(A)-(C)). Use the stay to link families to housing navigation and case management that can help turn a few nights of stability into longer-term solutions.

9.  Use attendance data to target and evaluate. Review a student’s attendance history before deciding whether short-term emergency housing is the right intervention; it may help reveal the causes of past attendance problems and whether unstable living arrangements are the barrier. Looking at these data across your caseload also can help you examine how emergency housing fits alongside the rest of your McKinney-Vento program.

10. Document both the demand and the impact. If demand outstrips funds, document unmet need — it is powerful evidence for local partners, your SEA, and federal advocacy. Similarly, document the impact of short-term emergency housing on attendance, stability, and academic performance to help make the case for more support from both public and private funds.

Sample Letter and Templates

The templates below are provided by SchoolHouse Connection for informational purposes and are not legal advice. Please review them with your business office and legal counsel to meet state and local requirements, and adapt them to your local circumstances. 

• Sample Informational Letter: Introducing Your Program to Local Motels/Hotels
• Sample MOU: Emergency Motel/Hotel Stays Through a Third-Party Partner
• Sample Rate Agreement Between an LEA and a Motel/Hotel for Emergency Stays

Resources

• U.S. Department of Education Dear Colleague Letter on short-term, temporary emergency housing under EHCY 
• U.S. Department of Education Non-Regulatory Guidance on the Education for Homeless Children and Youth Program
• NCHE’s Use-of-Funds Tip Sheet for Serving Children and Youth Experiencing Homelessness with Education for Homeless Children & Youth (EHCY) Program Funds
• Short-Term, Temporary Emergency Housing with EHCY Funds: Considerations for State Educational Agencies (PDF)
• Short-Term, Temporary Emergency Housing with EHCY Funds: Considerations for Local Educational Agencies (PDF)
• Archived webinar: Supporting Students Experiencing Homelessness Through Hotel/Motel Stays, featuring implementation lessons from San Diego County, CA and Milton, VT