What is the difference between how HUD and MN define homelessness?
Author: Betty | Date Created: December 12, 2025 | Date Updated:
What this is
This article will help you understand the difference between the two different definitions of homelessness in Minnesota.
The Difference Between HUD’s Homeless Definition and Minnesota’s Definition
In Minnesota, you will see two different definitions of homelessness: HUD's federal definition (narrower) and Minnesota state's definition. Both are correct and are used for different reasons. Knowing the difference will help you to connect your clients to the right programs and services.
How HUD defines homelessness
HUD’s definition is tied to federal program eligibility and has narrower criteria. Your client is considered homeless if they are:
Category 1: Literally Homeless
- In shelter
- Outside or in a place not meant for living
- In a hotel/motel paid for by a charity or government
Category 2: Imminently Homeless
- Will lose housing within 14 days
- No safe place to go, no supports
Category 3: Other Federal Statutes
- Mostly for youth programs
- Must be unstably housed, very low income, and have multiple recent moves
Category 4: Fleeing Domestic Violence
- Escaping violence with no safe alternative
Key Point: HUD does not count “doubled up” or situations of couch-hopping/staying with family or friends as homeless, except in very rare youth cases.
How Minnesota defines homelessness
Minnesota defines homelessness more broadly. Your client is considered homeless if they do not have a safe, fixed place to stay at night. This includes:
- Shelters
- Outside
- Places not meant for inhabitation
- Hotels or motels
- Staying with friends or family (“doubled up”)
- Couch hopping
- Leaving institutions with nowhere to go
- Fleeing domestic violence
Minnesota includes doubled-up situations because they are a major part of homelessness in the state.
Major Differences between HUD and MN State definitions
1. Doubled-Up - the largest difference
- HUD: Not considered homeless
- Minnesota: Considered homeless
2. Why different definitions?
- HUD: Determines eligibility for federal housing programs
- Minnesota: Used for studies, research, and some state services
3. Youth and Families
Minnesota considers many youth/families as homeless who wouldn’t meet HUD’s criteria.
4. Imminent Risk situations
- HUD: Must lose housing within 14 days
- Minnesota: No time limit
Why This Matters
Your client may be homeless under Minnesota’s definition but not eligible for HUD programs. It is important to understand the differences between the two definitions of homelessness to ensure you can explain eligibility options to your clients as you plan and advocate with them. It also helps with correct HMIS data entry.