Let’s End the Funding Competition and Devote Adequate Resources to End Homelessness NOW!

Across the nation, agencies and communities providing housing and services to homeless families and individuals with federal HUD funding are beginning the annual ritual referred to as the SuperNOFA.  This is not some astrological event.  Rather, it is the funding equivalent of a cross between the Hunger Games and Survivor.  Agencies receiving HUD homelessness funding are required to compete with each other to renew their grants for permanent supportive housing, transitional housing, rapid re-housing or other programs.  The losers will be defunded and “voted off the island.”

While competition for funding can be beneficial to ensure that the most worthy projects having the greatest outcomes housing the homeless are funded, the NOFA (Notice of Funding Availability) is structured in such a complex and convoluted way that it traumatizes not only agencies serving the homeless, but the very people the funding is designed to help — formerly homeless families and individuals who are currently residing in supportive housing funded by these grants.

The funding process requires local “continuum of care” entities designated by HUD to hold local competitions for new and renewal projects serving the homeless, and submit a collaborative application which ranks projects based on HUD and locally determined criteria.  The collaborative applications are then ranked by HUD, and projects prioritized by the local continua will be funded or not based on how HUD has ranked their continuum and how the continuum has ranked the project.

The process involves a three month scramble that starts with reading and understanding an 83 page NOFA issued by HUD which changes each year, the issuance of local continuum processes involving scoring matrices and priorities, the writing of new and renewal applications, the ranking of those applications by the local continua, and the submission of the collaborative application to HUD with ranking of local projects.

HUD then takes approximately three months to review, rank, and make announcements as to which projects will be renewed and which limited new projects will be awarded.

Thus, half of each year, agencies housing the homeless with federal funding are working on getting their grants renewed or worried about the prospects of their grants not being renewed.

This might be chalked up to just the “cost of doing business” if it were not for the fact that the final funding decisions are really not about which agencies are funded and not funded, but whether the families and individuals being housed through these programs will continue to be housed or not.  Indeed, the non-renewal of homeless housing by HUD over the past ten years has led to significant reoccurrence of homelessness by thousands of people previously housed in HUD funded programs.

Simply put, families and individuals housed in supportive housing programs funded by HUD should not have their continued housing put at risk for the sake of HUD managing a competitive renewal process.

To make matters worse, HUD has created a process whereby local continua must rank their projects into two tiers – with 6 percent of funding ranked in the second tier.  Projects ranked in the second tier are least likely to be refunded. 

HUD initially created a two tiered ranking system in 2012, when congressional appropriations for the program were significantly cut through the process known as Sequestration.  However, HUD has continued to use the two tiered ranking even though funding in the past few fiscal years has been sufficient to fund all renewal projects.

A yearly national competition for funding might be justified if there were significant funding for new projects each year.  However, the vast majority of HUD funding is needed just to renew existing projects housing formerly homeless persons.  In the 2018 competition, 91.3% of projects funded were renewal projects, with only 5.8% ($126 million) being new housing or service projects.  Of these 71% of renewals (totaling $2 billion) were for permanent supportive housing – applications to keep those who were housed through those projects remain housed.

There is no other funding process in the federal government that places the housing or services of people in need at risk through a competitive renewal process.  Can you imagine if HUD required Public Housing Authorities housing millions of people through public housing or Section 8 housing choice vouchers to annually compete to continue to receive such funding and keep those currently housed from losing their housing?

To make matters even worse, HUD has devised scoring criteria for the national competition that penalizes communities that are experiencing an increase in homelessness due to factors outside of their control.  For example, they provide incentive points for continua that demonstrate an overall reduction of at least 5% in the number of people experiencing homelessness, and for demonstrating a reduction of “first time homeless”.  Similarly, they provide incentive points to continua that demonstrate a reduction in the length of time people remain homeless, demonstrate a decrease of 5% of chronically homeless persons, or a decrease in family homelessness, and for a reduction in the number of homeless veterans.

While there is certainly merit in rewarding communities for improving outcomes, penalizing communities that are struggling with increased homelessness due to affordable housing shortages, increased population, decreased employment opportunities, and other factors out of their control is not only counterproductive, it exacerbates the problem by reducing the very resources these communities need to reduce homelessness.

In what world would it make sense for the Center for Disease Control to reduce its assistance to communities for treating HIV-AIDS or TB because there were more people in those communities needing such treatment?”  That is essentially what HUD is doing in its scoring process.

HUD claims that chronic homelessness has decreased by 26% since 2007, despite recent evidence of increased homelessness in many communities.  Even if true, at that rate, we will not achieve the end of chronic homelessness until 2050.  That is unacceptable in the richest nation on earth.

To truly help communities reduce and end homeless, significantly more federal funding is needed to help leverage state, local and community efforts.  To rely on only 5.8% of funding to provide new housing for people currently on the streets will not end homelessness. 

We need to demand that Congress significantly increase its funding for homeless assistance programs — to not only continue to house those previously housed who need continued assistance to remain housed, but also to provide new housing those currently living on the streets.  Incremental increases are not sufficient.   We must start with at least a doubling of the current homeless assistance program budget.

Congress authorized in the HEARTH Act of 2009 that funding to renew permanent supportive housing be funded through the Section 8 Appropriations Fund rather than through the more limited homeless assistance funding.  HUD has refused to implement this change.  Doing so now would free up over $1 billion dollars of funding to target the newly homeless.

HUD should also end its practice of requiring annual renewals for desperately needed homeless housing and services.

Finally, Congress must restore affordable housing funding across the board to levels necessary so that those experiencing homelessness are not continually competing for limited housing with those living at risk of homelessness and those working at minimum wage jobs. 

The time to act is now.

The U.S. Department of Housing and Urban Development (HUD) is expected to publish later this week in the Federal Register interim regulations for the new Continuum of Care (CoC) program under the HEARTH Act and a summary of these regulations.

Eligible activities & program requirements of the CoC program addressed in the regulations are:

  • Permanent housing ( PSH for people with disabilities and rapid re-housing) (PSH)
  • Transitional housing (TH)
  • Supportive Services Only (SSO)
  • Homeless Management Information Systems (HMIS)
  • Prevention (For High Performing Communities designees)

“HUD expects the regulation to be published in the Federal Register in the coming week. The interim regulation will be effective 30 days after publication in the Federal Register. The final Homeless Definition is in effect for administration of the CoC Program interim rule.” -HUDHRE.info

Read the Regulations and Summary

By Michael Stoops

Over the past several decades, the usage and connotation of the term ‘safety net’ has changed, but the need has only increased. The ‘safety net’ encompasses various programs, such as Medicaid for children and families, Medicare for the elderly, Food Stamp Programs and more. The National Coalition for the Homeless has always been in support of safety net services as vital resources for preventing and ending homelessness, and giving our neighbors the dignity to feed and care for themselves and their families. NCH’s support of the safety net is best illustrated through our newsletter, Safety Network, which was sent out from 1981 through 2006. Although the name for the newsletter was chosen based off former president Ronald Reagan’s quote on the safety net, the usage and attitude towards the safety net has undoubtedly transformed over the past few decades, as demonstrated by the quotes below.

When he announced his budget proposals Feb. 18, in an address to a joint session of Congress, President Reagan declared: ”We will continue to fulfill the obligations that spring from our national conscience. Those who through no fault of their own must depend on the rest of us, the poverty-stricken, the disabled, the elderly, all those with true need, can rest assured that the social safety net of programs they depend on are exempt from any cuts.”   President Ronald Reagan, February, 1981.

Former U.S.  Rep. Cynthia McKinney, Green Party Presidential Candidate 2008, at a Citizen’s Commission on 9/11, stated that “this time, not just for supporting me, but also for not being bamboozled into submission by questionable insider backroom characters who want to take away our freedoms, send our children off to war, and rip to shreds the social safety net for the American people.” September 2004.

President Barack Obama, during his senator years, said that “Privatization is not something that I would consider. And the reason is this: Social Security is the floor. That’s the baseline. Social Security is that safety net that can’t be frayed and that we shouldn’t put at risk.” July 2007

Ron Paul, Republican Presidential Nominee, is opposed to the safety net. He thinks that “it does work for some people, but overall it ultimately fails, because you spend more money than you have, and then you borrow to the hilt. Now we have to borrow $800 billion a year just to keep the safety net going. It’s going to collapse when the dollar collapses, you can’t even fight the war without this borrowing. And when the dollar collapses, you can’t take care of the elderly of today. They’re losing ground. Their cost of living is going up about 10%, even though the government denies it, we give them a 2% cost of living increase.”  Newsweek interview by Howard Fineman, December 2007.

“For people who have for been putting their hard-earned money into the system for years, the president’s idea would replace their safety net with a risky gamble with no assurance of a stable return of investment.” – U.S. Rep. Grace Napolitano  for California’s 38th congressional district March 2009.

 “I understand that during this financial crisis, when countless numbers of our family members, neighbors, colleagues, and friends have seen their retirement savings disappear, the safety net of Social Security is more important than ever. The Congressional Budget Office has estimated that next year, for the first time since 1975, beneficiaries will not get a cost of living adjustment. I support emergency measures to ensure that beneficiaries receive a cost of living increase, ensuring that social security’s promises are kept. As Senator, I will fight to keep the promise of Social Security and preserve it for future generations. I am committed to ensuring that benefits are not reduced, and that those paying into the system now will be guaranteed their benefits later.”  -Martha Cloakey, Democratic nominee from MA for special election in the Senate and current Attorney General of MA, December 2009.

“Democrats know that the simple math of health care will eventually shred the social safety net they seek to protect.’” National Republican Congressional Committee (NRCC), Washington Post, June 2011.

California U.S. Rep. Barbara Lee, former chairwoman of the Progressive Caucus, said she has faith in Obama’s ability to cut a fair deal, but when asked about potential cuts to Medicaid, Lee said, “No, you can’t cut that.” “That’s a safety net, really,” Lee told POLITICO.  – U.S. Rep. Barbara Lee, U.S. Representative for California’s 9th congressional district, June 2011.

“Social Security is America’s social safety net for the elderly and disabled. The program was enacted in 1935 in the midst of the Great Depression as part of the New Deal. While it initially sparked controversy, it has over seven decades proved to be a success, providing needed benefits to millions of Americans in need and serving as a source of retirement income for America’s middle class.” – Republican Texas Governor Rick Perry’s Proposal to turn Social Security over to the States, from White Paper, September 2011.

“I’m not concerned about the very poor. We have a safety net there,” Romney told CNN. “If it needs repair, I’ll fix it. I’m not concerned about the very rich, they’re doing just fine. I’m concerned about the very heart of the America, the 90 percent, 95 percent of Americans who right now are struggling.” Republican Presidential Candidate Mitt Romney, January 2012

“What the poor need is a trampoline so they can spring up, so I am for replacing the safety net with a trampoline.” – Republican Presidential Candidate Newt Gingrich, February 2012.

Republican U.S. Rep. Allen West (FL) is disturbed that food stamps buy much more than food these days.  “I happened to drive by a gas station in Pompano Beach, Fla., in the heart of Congressional District 22, the district I represent.  In front of the gas station were large banners proclaiming, ‘We accept EBT SNAP cards.’  This is not something we should be proud to promote,” the Florida Republican said.  “Now we see a growing number of businesses in this country, including sit-down and fast food restaurants, standalone and gas station convenience markets, and even pharmacies eager to accept SNAP benefits, Rep. West observed.  “The measure of success for our social safety net programs should be that fewer and fewer Americans must rely on them, not more and more,” he added.  – Washington Times April 2012.

From Ann Marie Oliva, Director, Office of Special Needs Assistance Programs, U.S. Department of Housing and Urban Development (via the CPD homeless listserv)

In September of last year, HUD held two national conferences to begin the process of familiarizing communities with the policy and performance requirements that will govern the new HEARTH Act programs.  In the plenary session, we briefly discussed the connection between the roll-out of the new programs authorized under HEARTH and the appropriation levels HUD  may receive in this and the coming years.  As you are probably seeing in the news, the budget situation has changed since September – which has an impact on the high-priority items we are working on in SNAPS, including the HEARTH regulations and the 2011 competition.

Fiscal Year 2011 has thus far proven to be a challenging year, and we at HUD know and understand that the uncertainty about the 2011 budget has been a matter of great concern to our grantees and stakeholders.  We also know that you were expecting to see, in the near term, the new regulations for the Emergency Solutions Grants, Continuum of Care, and Rural Housing Stability programs.  I want to take a moment to update all of you on the budget and how it has affected our plans to implement HEARTH.  Let me summarize for you where we stand on these critical items:

FY2011 Budget:

  • As is the case in all federal agencies, we are awaiting a final FY2011 appropriation from Congress and have been operating under Continuing Resolutions, the most recent of which expires March 18.  Because we do not know the final funding level for FY2011, ESG formula funds (which are usually released along with other formula programs early in the year) have not been released.
  • There are several possible scenarios regarding the budget amount for 2011, and HUD is working to ensure that we have viable options for each scenario that minimizes the adverse impact – if there is one – on CoCs and grantees.  Developing planning options for whatever scenario becomes reality is our priority at present.  This includes how and when we will conduct the 2011 Continuum of Care competition and what elements of HEARTH can be included in the competition.
  • Last week’s House-passed appropriation (H.R.1 — a full-year Continuing Resolution) held HUD’s targeted homeless programs steady at the 2010 funding level.  At that level, HUD projects that ESG and competitive renewals can be funded.  However, the HEARTH Act could not be fully funded.   We commit to providing you with as much information as possible once it becomes clear what the funding level will be.

HEARTH Regulations:

  • We continue to move the regulations through the clearance process, which includes review and approval by several different offices within HUD and with Office of Management and Budget.  Until the new regulations are released and effective, grantees must continue to use the current regulations. This includes the definition of homelessness.
  • HUD is in the final stages of clearance for the new definition of homelessness, which will include changes made in response to the public comments that we received last summer.  HUD plans to provide training on the new definition and will clearly state when the new definition will be effective.
  • As stated above, the 2011 appropriation level will determine, to a large extent, what provisions of HEARTH can be implemented in 2011 and what the process will be for implementation of the regulations.  For example, although HEARTH allows for increased administrative dollars for projects and planning funds for CoCs, those provisions can only be implemented if there are sufficient funds to cover those costs.  Consequently, only when the 2011 budget is finalized will HUD be able to communicate its plans for this year’s funding.

Although the current situation is challenging for all of us, HUD is focused on providing communities with the resources needed to successfully implement HEARTH within the limits of the final appropriation for FY2011.  In the coming months, we will be launching a comprehensive self-assessment tool for CoCs to use to help identify where strategic planning efforts should focus at the community level.  We will also be launching other technical assistance tools and resources over the rest of the year.

HUD will continue to keep you informed of our progress and of the impact of the FY2011 budget process.  I encourage all CoCs to continue conducting strategic planning conversations, because these conversations will be critical for the successful local implementation of both HEARTH and the Federal Strategic Plan to Prevent and End Homelessness.