The National Affordable Housing Act (NAHA) of 1990 requested HUD to study the feasibility of allocating homeless assistance by formula and to submit its recommendations in a report to Congress. At the beginning of its inquiry, the Department hosted a meeting of researchers and others knowledgeable in the field of homelessness. Although very little support for a formula allocation was expressed at the meeting, the discussion did lead to an examination of four direct measures of homelessness that might be used as a basis for a formula and several other indirect measures as potential proxies for homelessness. From the four direct measures, the shelter portion of the Census Bureau's Street and Shelter (S-Night) count was chosen as the most valid basis for a formula. A formula was constructed using the S-Night shelter count, and the allocation of funds under this formula was compared with the current distribution of HUD homeless assistance funds.