The U.S. Interagency Council on Homelessness announced in June that it would be working to update the coordinated Federal plan to end homelessness. Comments were solicited via the USICH website, though now, all mention of this comment process have been removed.
Below are the concerns and comments that the National Coalition for the Homeless shared:
NCH Comments on the Federal Strategic Plan to End Homelessness
Submitted to the US Interagency Council on Homelessness July 2020
Thank you for your efforts to revise the Federal Strategic Plan to End Homelessness, and to gather comments from stakeholders. However, the National Coalition for the Homeless (NCH) is concerned that the US Interagency Council on Homelessness is not soliciting input from a broad enough audience, nor in a transparent process that includes people who have experienced homelessness as key drafters.
After nearly four decades of advocacy on behalf of those experiencing homelessness, NCH believes that any further Federal Strategic Plans to End Homelessness must be made in direct partnership with people who lived the experience of homelessness. The true experts, people with this “lived experience” of homelessness know first hand the effects of Federal policy and as such, can hone in on what changes can be made to achieve the goal of ending mass homelessness in the United States.
Further, any Federal Strategic Plan to End Homelessness must:
- Have clear and quantifiable goals, objectives and action steps. The plan should include a timeline, parties responsible for implementation, and a description of funding needs and sources.
- State that housing is a civil and human right, as a safe, stable home is the foundation for human development, student achievement, economic survival and community health.
- Identify the systemic causes of homelessness, including structural racism, redlining, and other disinvestment in black and brown communities. The plan and its objectives should be written with a clear equity lens.
- Affirm that any efforts to criminalize people, or the daily survival acts of people, who live outdoors – things like urban camping bans, food sharing restrictions, and limits on when and where people can sit or lie down – are counter-productive, cause trauma, and should be halted or reversed in city code.
If you were to propose one new initiative that the federal government is not doing now what would it be?
- Fund Permanent Supportive Housing from the Housing Choice/Section 8 Program (with program changes that provide flexibility for criminal/credit/tenant issues)
- Do not dismantle COVID-19 response networks, maintain the CDC guidelines for encampments including access to sanitation and water
- Decisions and priorities on use of funds should be locally driven not HUD driven
- Return to funding transitional housing, both in scattered sites and through rental assistance
Outside of prior USICH federal strategic plan focuses, what else might the federal government do to prevent and/or reduce homelessness?
- Increase workforce development programs that train people experiencing homelessness as Peer Advocates to supplement the current homeless provider workforce.
- Listen to people who have/are experiencing homelessness and include at decision making tables on types of programs that work.
- Equity in funds – ensure tax credits, bonding, appropriations, etc. reserve funding for people at risk of or experiencing homelessness and rental housing at below 30% of median income
- Strengthen the interagency coordination of resources for livable incomes and employment (both FT and part time/contracted/gig/piece work and migrant/day labor) and public assistance including unemployment, SSI and Social Security.
- Universal Health Care/Immediate and voluntary access to medical services for all individuals, youth, families experiencing or at imminent risk of homelessness.
- A guaranteed opportunity for permanent housing that is affordable at their income for all individuals, youth, families experiencing or at imminent risk of homelessness.
What is one activity the federal government is doing that you believe should be deprioritized?
- Coordinated entry – Implementation is inconsistent and costing millions in HUD TA, and systems often lead to discriminatory and unethical service delivery
- Point in Time count – It is archaic and an inaccurate system- does not count people in programs where most of the homeless funding is going to: permanent supportive housing and rapid re-housing
- HMIS –violates Data Privacy, HIPPA laws
- HUD controlled process of how funds should be used by communities
- HUD’s homeless definition -utilize one homeless definition (the Department of Education’s definition or similar) across all agencies.
What is one activity that the federal government is doing well and that should be prioritized?
- The Youth Advisory Boards Model should be implemented in the Adult population. People who have/are experiencing homelessness need to be voting decision making members of the Federal and all State Interagency Councils and at CoC level and funded agencies.
- The Veteran model that includes dedicated vouchers (VASH), Transitional Housing, workforce development (HVRP, CWF), Healthcare to scale and prevention (SSVF) should be mirrored that can be accomplished with substantial increases for targeted homeless programs through HHS and DOL.
Overall, what would you say the top 3 federal priorities should be as they relate to preventing and ending homelessness?
- Listen to people who have/are experiencing homelessness. Decisions and priorities on use of funds should be locally driven with people who have/are experiencing homelessness not HUD driven.
- HUD programmatic changes: Funding Permanent Supportive Housing from the Housing Choice/Section 8 Program (with program changes that provide flexibility for criminal/credit/tenant issues), Rapid Re-Housing must include a livable income component to be able to pay rent after subsidy ends (employment and /or public assistance access/ housing assistance)
- Creating a Unified definition of homelessness across federal agencies and Immediate and voluntary access to emergency housing/shelter for all individuals, youth, families experiencing or at imminent risk of homelessness.
In terms of homelessness, what areas are in need of greater attention at the federal, state, and local levels?
- Affirm the Right to Housing and protection of the civil rights of people experiencing homelessness.
- Listen to people who have/are experiencing homelessness and include at decision making tables on types of programs that work.
- Fund Expanding Affordable Housing Stock to Pre-1970 Levels.
- Expand and fund the use of innovative housing approaches: Tiny Homes, Shared Housing, Small Market FMR’s, Community Choice in Service Delivery, homeownership, scattered site/rent subsidy transitional housing
- Expand homeless prevention to include eviction protection, a right to counsel, and cash assistance
- Universal Health Care
- Expand fair housing protections to prevent rental redlining and source of income discrimination.
- Coordination and placement into housing opportunities that are affordable for people being discharged from correctional/ mental health/chemical health/physical health/etc. institutions.
