Arguments and Rebuttals - Amending the HUD Homeless Definition

There’s not enough funding to meet those who meet the current HUD definition of homelessness. HUD programs are turning people away.

 Defining a problem by the funding currently available to address it is nonsensical. Congress needs to know who and how many people are without housing in order to devise effective solutions.  A narrow definition of homelessness does nothing to reduce the number of people living without their own homes. It simply gives policymakers an unrealistic view of the scope of the problem. On the other hand, an accurate definition brings new stakeholders to the table to support broad-based solutions. For example, with a definition of homelessness that includes children, youth, and families served by early education and public school programs, important voices such as teachers, school social workers, and parent groups can be mobilized to help reduce homelessness.

Broadening HUD’s definition of homelessness will take services away from people in shelters and on the streets.

 Amending the HUD definition, per HR32, will not require communities to spend HUD funding on doubled-up and motel families and youth. It simply gives them the flexibility to do so when these families and youth need HUD homeless services.  HR 32 broadens HUD definition to include only children and youth (and their families, if appropriate) verified as homeless by four federal programs that use a broader definition of homelessness. While not all of these children and youth may need HUD homeless services, those who do need HUD homeless services are currently prevented from receiving it simply by virtue of where they are staying.  The new HEARTH Act requires communities to comprehensively assess the housing and service needs of people who are homeless, and develop plans to address gaps that are identified. HUD has demonstrated over time that communities will be rewarded for good planning and attention to meeting identified needs. There is no reason to believe that HUD will retreat from this position, so communities will remain free to target any population of homeless persons, as long as there is clear evidence of unmet need.

People on the streets and in shelters are more vulnerable than those who are doubled-up and people who are in self-paid motel situations.

 Children and youth in doubled-up and motel situations are extremely vulnerable, living in precarious, unstable, and sometimes unsafe conditions. They may suffer the life-long impacts of toxic stress if their living situations are not stabilized.  Vulnerability determinations must be done on a local, individual basis, after gathering as many facts as possible – not by Congress. HR 32 allows all highly vulnerable living situations, especially for children and youth, to be considered in making these decisions.

The education definition of homelessness is overly broad; it includes all households who are sharing housing because they are poor.

 Children and youth in doubled-up situations are only considered homeless under the education definition if they are sharing the housing of others due to loss of housing, economic hardship, or a similar reason. People who are sharing housing in permanent, adequate, and voluntary arrangements do not meet the education definition of homelessness.

People in doubled-up and self-paid motels can be served under the new HEARTH Act definition of “at risk” through Emergency Solution Grant funds.  People defined as “at risk” are only eligible for 3% of all HUD Homeless Assistance dollars - this year, that is only $50 million nationwide.1  People defined as “at risk” are not eligible for permanent housing or supports like job training, mental health, and substance abuse treatment – services they desperately need to escape homelessness. Only people who meet HUD’s definition of homeless are eligible for those services.  People defined as “at risk” are not included in homeless counts and thus are overlooked in planning to address "homelessness" in the community.

If the HUD definition is broadened, per HR 32, communities will “cream” to show good results: they will prioritize doubled-up and motel families and youth and neglect those who are harder to serve (those on the streets and in shelters).

 The Continuum of Care process is designed to allow communities to determine their own needs, and to account for all homeless populations. HUD is supposed to rank these applications according to their plan for meeting greatest needs. A rigorous and thorough grant application and review process, as well as other

1 The Emergency Solutions Grant (ESG) is $250m out of the current HUD homeless assistance appropriation of $1.9billion – slightly more than 1/8 of total HUD homeless funding. HR2112- Consoldated and Further Continuing Appropriations Act, 2012. However, at least half of ESG goes to emergency shelter. Hearth Act – requires hold harmless ESG spending on emergency shelter, up to a max of 60%. People “at risk” of homelessness are not eligible for emergency shelter. If you're at risk of homelessness you're not in emergency shelter. So let's call it 50%. That puts us at $125m out of $1.9b. Now recognize that ESG can go to both homelessness prevention and rapid-re-housing. Rapid re-housing is only for people who are already homeless - not at risk. Let's say that half of the remaining ESG goes there. HUD I know would like that to be the case. Now you're at $62.5m. Then, some of the homelessness prevention money can go to the people we got added to the definition of homeless - the doubled up with multiple moves and all of them. Who knows how much to lop off there, but let's say $5m (being conservative). So $57.5m Plus some ESG money goes to HMIS. Let's say $5m, though I bet it might be a bit more. So now we are at $52.5m. That's 2.75% of all HUD homeless assistance funding. accountability measures, is the best way to ensure that the needs identified by local communities are addressed by those communities.  The severity of a family or youth’s problem cannot be determined by where they happen to stay on a particular night. Many families and youth cycle through various homeless living situations, including motel and doubled-up; where they are staying does not determine how hard it is to serve them. For children and youth, doubled-up situations may create the greatest barriers to services and to safety, because they are so hidden.

The HEARTH Act is only now being implemented; regulations were issued just weeks ago. It is premature to make any changes to the definition until the new HEARTH Act definition is given a chance.

 The regulations issued by HUD render the broadening of the statutory definition of homelessness in the HEARTH Act almost meaningless. The documentation requirements will be impossible for families and youth in doubled-up and self- paid motel situations to meet. Therefore, new legislation is necessary.