How can the Federal government plan to End Homelessness?

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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:

  1. 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. 
  2. 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. 
  3. 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. 
  4. 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.

The National Coalition for the Homeless (NCH) celebrates the Supreme Court decision earlier this week that the 1964 Civil Rights Act protects gay, lesbian, and transgender employees from discrimination based on their sexual orientation or gender identity.  Young people who identify as gay, lesbian, bisexual, transgender or gender nonconforming, are 120% times more likely to experience homelessness than their cisgender and straight peers. This disparity is caused by mistreatment by family as well as institutions, and discrimination not just in employment, but also in access to housing, health care and education. 

“[This] ruling by the Supreme Court is a monumental victory for LGBTQ people across the United States. Discrimination in employment is a critical barrier to safe and secure housing for LGBTQ youth and adults,” says Gregory Lewis, CEO and Executive Director of True Colors United. “Discrimination against someone based on sexual orientation or gender identity is sex discrimination. This ruling makes clear that efforts underway at the Department of Housing and Urban Development to undercut protections for transgender people experiencing homelessness should not be allowed to continue under the law.”

NCH has long supported inclusive access for LGBTQ people to shelter and other emergency services. In 2003, along with the National Gay and Lesbian Task Force, we authored a guide for how shelters can make their agencies safe for people who identify as transgender. A ground-breaking survey of transgender Americans in 2015 found strong economic disparities for transgender people. Nearly one in three, (29%) of respondents were living in poverty versus 14% of the general population, and 30% reported having experienced homelessness at some point in their lifetime. As recently as 2016, HUD itself published guidance for shelters requiring that transgender residents are accepted to single-sex shelters based on their gender identity, without regard for what may appear on someone’s state identification. 

But after insensitive and discriminatory comments about transgender people made by Secretary Ben Carson, HUD has shown intention to roll back the 2016 guidance for shelters. A proposed rule will likely be published in the coming weeks that would allow single-sex shelters to judge gender by biology, and not by someone’s self identity.  

According to the Transgender Law Center, “This situation is particularly dangerous for transgender women who are inappropriately placed in men’s shelters where they often subjected to inhumane and degrading treatment and abuse, including sexual assault. While some transgender people will run the high risk of facing harassment and violence in a shelter that doesn’t match their gender identity just so that they can be housed for the night, others in this situation will simply forgo shelter and sleep on street.”

NCH firmly rejects any attempt to deny safe access to shelter or other resources for transgender and gender nonconforming people, especially transgender people of color, who disproportionately experience housing instability, discrimination and violence.

For more visit:
Info on Black Trans Advocacy Organizations
Lambda Legal
True Colors Fund

 

Our Nation and the World are fearful of the uncertainties of the COVID-19 pandemic, and our hearts go out to George Floyd, his loved ones and all of us who are hurting right now. The massive protests that are taking place across the globe, are revealing years of pent-up frustration with racism and inequality. The militarization of policing in the United States and the repeated acts of violence against people of color by the police, creates a combustible threat—one that strikes at the very foundations of our democracy.

NCH stands in solidarity with those in America who are not satisfied with a society that fails to denounce the structural racism that plagues our nation.  As many of us watched in horror as George Floyd was murdered right in front of our eyes, or Ahmaud Arbery, who was hunted down and murdered on video, or Breonna Taylor who was shot and killed in her own home, we are reminded of many more precious lives taken by the hands of law enforcement – those who are trusted to protect us.

Repeatedly, we hear anguished cries as one more black or brown person takes their last breath, too soon. We are reminded of the reality that until we address structural racism in this country, these horrendous images will continue as nightmares in a never-ending loop.

As we battle multiple crises, the COVID-19 pandemic, the senseless death of yet another black man at the hands of law enforcement, and an attack on our civil liberties, we pray for everyone’s safety and health. We must remain vigilant stewards in hopes of an America and World filled with peace, equality, and justice for all.

Donald Whitehead
Board President
National Coalition for the Homeless

The National Coalition for the Homeless applauds all the communities that are rushing to provide desperately needed housing for people who are unhoused, and especially vulnerable to contracting and succumbing to COVID-19. 

However, we are, quite frankly, disturbed that so many are still relying on congregate settings: big tents and open floor warehousing of people, in what is clearly a dire public health emergency for the entire country. In the hopes of relieving the strain on other overcrowded shelters, the San Diego government decided to open the convention center to the homeless population. They are expecting to house over 1,500 people during this crisis. San Francisco ignored early warnings from advocates and requests to place vulnerable folks in empty hotel rooms, and now residents and staff of shelters are falling ill. This is unacceptable. We are clearly failing to prevent the spread of COVID-19 in both sheltered, and unsheltered, populations, and in direct opposition to clear guidelines given by the CDC (Centers for Disease Control and Prevention). 

Researchers who have long studied homelessness have projected that homeless individuals infected by COVID-19 would be twice as likely to be hospitalized, two to four times as likely to require critical care, and two to three times as likely to die than the general population. (Read the full report)

This crisis continues to highlight the structural inequities that have plagued us for decades, causing mass homelessness since the defunding of Federal affordable housing programs starting in the 1970’s. 

We call on Congress to respond swiftly with the following: 

  • 11.5 billion for ESG (15 bil based on this study, minus the $4bil in the CARES Act) 
  • 4 billion for fair elections (based on this information) 
  • Emergency rental assistance for all tenants, including rural renters
  • Extend moratoria on evictions to all renters, extend sunset date to 3 months after stay-at-home orders are lifted, and do not require all back rent paid when moratorium lifts 
  • Extend health care for uninsured/underinsured 
  • Extend funding for hotel/motel space for people who do not have a permanent home
  • Facilitate transfer of unused/vacant housing to families who are unhoused 
  • Increase food assistance through the SNAP program

Further, we call on HUD either to automatically renew all FY 19 funded COC projects, or greatly simplify the renewal process. Our service providers are using all their capacity to ensure their unhoused community members are safe, we don’t need a lengthy application process during this public health crisis!

But again, let’s be clear, homelessness has been a public health emergency for over 4 decades!!

We stand in solidarity with our neighbors who are calling to #CancelTheRent. They know so well that the over 22 million Americans who have filed for unemployment, plus the up to 140 million Americans who were already on the edge before the coronavirus appeared, are in danger of becoming homeless. 

We stand in solidarity with all those who have been left out of the Federal relief responses thus far, our poorest and most vulnerable neighbors. As Rev. Dr. William Barber puts it, “The virus is teaching us that from now on, living wages, guaranteed health care for all,unemployment and labor rights are not far left issues, but issues of right vs wrong, life vs death.”

We must work to correct the long-standing and systemic causes of housing, income, health and further racial inequities. When the emergency of Coronavirus infection has passed, we do not want to return to normal. We should all hope to see a new normal emerging where we and all of our neighbors have safe, affordable and accessible housing; adequate wages to cover our living expenses, adequate and affordable health care, and where our civil and human rights are equally defended and protected.

NCH members sent over 1,600 letters to Congress urging greater relief and stimulus for homeless and at-risk communities. Thanks in part to this action, the Federal government has now enacted the third stimulus package for COVID-19, known as the CARES Act. While this is an important step in providing relief to people who are economically vulnerable, there is still much more needed to keep our communities healthy, housed, and safe. Notably missing were increases in food assistance, adequate health and housing support for Americans losing their jobs, and enough support to house our vulnerable homeless neighbors.

The CARES Act included $4 billion for Emergency Solutions Grants (ESG). This money can be used for shelter for short term and medium term housing assistance such as Rapid Rehousing. Usually with ESG grants there is a state matching component, but this component has been waved for purposes of this emergency funding. Of the total, $2 billion will be released as soon as possible under the pre-existing formula. The last $2 billion will be released based off of community needs, an assessment of which will be forthcoming.

Also included is $5 billion in Community Development Block Grants (CDBG). Similar to the ESG funding this money will be distributed in waves. There will be $2 billion released to states and communities based off of the fiscal year 2020 formula. One billion will be released to states and another $2 billion will be released to states and local governments based on risk and housing disruptions.

Further funding:

  • $1.25 Billion in tenant based rental assistance
  • $1 billion for Project Based Rental Assistance (PBRA)
  • $300 million in tribal housing grants
  • $120 million for 202, 811, and HOPWA housing
  • 2.5 million for fair housing
  • $30 billion in Disaster Relief Funds
  • $150 Billion in flexible funds for states and municipalities that can be used for rental assistance and other community development needs
  • $3 billion for rental assistance for Public Housing Authorities.

Also included in this bill is a 120 day moratorium on evictions. However, this moratorium only covers renters living in public housing or project-based rental assistance programs. The majority of renters renting from private landlords would not be covered. The moratorium on evictions only applies to new filings of evictions. This means if you are already scheduled to be evicted this moratorium will not protect you. Also this law only protects people who have not paid rent. All other forms of evictions are not included.

This is a great first step but we need much more to protect our most vulnerable. Here are the policy asks the National Coalition for the Homeless is calling for:

  • Cancel the FY2020 COC NOFA
  • Emergency rental assistance for all tenants
  • Ensure moratoria on evictions do not lead to mass evictions after the emergency has passed
  • Extend health care for uninsured/underinsured
  • Extend funding for hotel/motel space after the emergency passes
  • Facilitate transfer of unused/vacant housing to families who are unhoused
  • Increase food assistance through the SNAP program

YOUR ACTION IS STILL NEEDED!

 Thank you all for your great work during this difficult time. Stay safe.

Related issue areas:
Fixing Unemployment Insurance
Disaster Loans for Small Businesses and Nonprofits

We applaud Congress for passing the Families First CoronaVirus Response Act, which will provide immediate paid sick leave and paid family leave to millions of people, expanded unemployment insurance, vital nutrition aid, more Medicaid funds for states, and free COVID-19 testing.

Image by Western Regional Advocacy Project

Image by Western Regional Advocacy Project

But they left out critical resources for people experiencing homelessness!!

Our unhoused neighbors are more likely to have underlying health conditions, use spaces with congregate settings (public transportation, shelters, soup kitchens), have already diminished life-expectancy, have limited ability to follow public health advice, or suffer from stigma and discrimination in accessing basic services. (Read more in the National Health Care for the Homeless Council‘s issue brief)

It is imperative that services, medical care, resources, and support for people experiencing homelessness is included in any further Federal Coronavirus response. 

We are all in this together – we must act now! 

We are asking for lawmakers to:

  1. Provide $15.5 billion specifically targeted to people who are currently homeless. This should include language that adds “medical respite care” services into allowable/prioritized uses for emergency CoC funding.  

  2. Cancel the 2020 NOFA: Direct HUD to automatically renew Continuum of Care Homeless Assistance Funding in 2020 to programs that were recently renewed through the 2019 renewal process, as currently allowed in the HEARTH Act, so long as the Continuum of Care Entity documents that a) there is a continuing demonstrated need for the project and b) that the project continues to comply with CoC program requirements.  Use the 2020 CoC NOFA process to competitively award only additionally appropriated funding for New Projects to meet the needs of those currently on the streets, in shelters, or the newly homeless.

  3. Require HUD to increase flexibility to allow communities to utilize CoC Homeless Assistance Funding to meet local needs and local priorities.

  4. Call for a moratorium on all homeless encampments sweeps during the pandemic. The CDC has released guidelines saying encampments should not be displaced unless housing is available

  5. Provide $50 Billion of new funding for expansion of Low Income Housing Tax Credits targeted to housing for homeless families and individuals, expansion of the National Affordable Housing Trust Fund, and expansion of Project Based Section 8 funding for permanent supportive housing and housing for families experiencing homelessness.

These demands are absolutely imperative to the safety, wellbeing, and care of people experiencing homelessness, and we cannot wait. Contact your Legislator below!

 

3/13/2020

As communities across the United States continue to respond and react to the growing Coronavirus (COVID 19) pandemic, the National Coalition for the Homeless today issued the following update to its members, supporters, policy makers, and people experiencing homelessness concerned about the public health crisis and its potential impact on people experiencing homelessness on the streets or in emergency shelters:

  1. It is important to recognize, and it cannot be overstated, that exposure to and infection by the Coronaviris is a community-wide problem that potentially affects all Americans, regardless of income and housing status.   However, people experiencing homelessness may be at greater risk of exposure and may be more vulnerable to the effects of the virus due to their homelessness – whether living on the streets, in encampments, or in crowded shelters.
  2. One of the most common recommendations of the CDC for limiting exposure to the virus – social distancing – is nearly impossible for those experiencing homelessness in most communities due to congregate emergency shelters and encampments those experiencing homelessness are forced to rely upon.  Additional housing options must be immediately deployed to lessen the risk of exposure and rapid community spread among the homeless population.
  3. Addressing the impact of the Coronaviris pandemic is a public health emergency that must be led by public health expects in our communities, states and at the Federal level through the Center for Disease Control.  Shelter and emergency service providers should not be called upon to divert limited resources needed to address the needs of the broader homeless population to address the Coronaviris impact within the homeless community.  Rather, public health responses must direct increased resources to meet the elevated and unique needs of those experiencing homelessness.
  4. Those who may be experiencing homelessness would not be in as great a risk of poor health outcomes, or spread of COVID-19, if they had access to safe, decent, affordable and accessible housing. We still have a lot of work to do to address the underlying income inequality and lack of low-cost housing that has perpetuated homelessness for decades.
  5. We must ensure that national, state and community-level public health planning efforts includes the homeless service agencies and those experiencing homelessness in the planning and responses.
  6. Public Health officials should provide adequate protective gear as needed, and include the safety homeless service workers and volunteers in their planning and implementation responses.
  7. Cities should provide hygiene facilities (port-a-potties, hand-washing stations) and trash pickup for residents of encampments – during and after any pandemic has passed.
  8. There should be a moratorium on encampment sweeps that displace already displaced households and that often cause the loss of personal property that includes medication and other life-sustaining items.
  9. All tests, treatment and quarantine locations should be offered without cost for all members of the community – housed or not, with or without health insurance.
  10. Each community should identify space that those who do not have a permanent home can access in case of quarantine. Any costs should come out of community-level public health resources.
  11. We must not divert limited funding for homeless services to be used to provide quarantine, testing or treatment. Homeless services are already woefully underfunded, and widespread homelessness is ALREADY a public health emergency!  Additional funding should be devoted by federal agencies to address the unique needs of those experiencing homelessness.

We further call upon Congress and the President to include in any emergency spending package to address the pandemic or the economic impact of such to include resources targeted to address the special needs of those experiencing homelessness, and those at risk of homelessness.  This should include a significant increase to emergency and homeless assistance funding through HUD, resources to prevent evictions due to the economic fallout, and increased public health and health care resources targeted to those experiencing homelessness.

We encourage those working with people experiencing homelessness, and those concerned about the impact of this pandemic on them, to utilize the following resources to develop appropriate outreach and treatment responses:

Coronavirus Resources

Centers for Disease Control and Prevention (CDC)

Health Resources and Services Administration (HRSA)

Department of Housing and Urban Development (HUD)

Updated 3/10/2020

With any public health or natural disaster emergency, those who are unhoused are often more at risk for poor health outcomes or other trauma. We understand that spread of communicable disease is much easier without adequate access to hygiene facilities or a safe home, so we wanted to share a few resources for those experiencing homelessness or service providers. 

The current outbreak of the novel corona virus that started in China spreads much the same way as the flu, through person to person contact, especially through droplets in the air produced when an infected person coughs or sneezes. Symptoms can include: fever, cough and shortness of breath.

The Centers for Disease Control (CDC) believes at this time that symptoms of COVID-19 may appear in as few as 2 days or as long as 14 days after exposure. Most infections in healthy children and adults are mild, the greatest danger is with those who have health conditions that limit the capacity of one’s immune system.

While there are no confirmed cases of COVID-19 infection in someone experiencing homelessness in the U.S., we are concerned that people who already lack ready access to hygiene facilities, a safe home and in many cases, adequate health care, will be especially vulnerable to complications from the spread of the virus. To prevent spread of the virus, the CDC recommends washing your hands often with soap and water for at least 20 seconds, especially after going to the bathroom; before eating; and after blowing your nose, coughing, or sneezing. If soap and water are not readily available, use an alcohol-based hand sanitizer with at least 60% alcohol. Always wash hands with soap and water if hands are visibly dirty. 

But what if you don’t have anywhere to wash your hands, or a home to stay away from crowds?
 Read: What if you can’t stay home?

Our recommendations:

  • More broadly realize that everyone who may be experiencing homelessness would not be in as great a risk of poor health outcomes, or spread of COVID-19, if they had access to safe, decent, affordable and accessible housing. We still have a lot of work to do to address the underlying income inequality and lack of low-cost housing that has perpetuated homelessness for decades.
  • Ensure that national, state and community-level public health/pandemic planning and response includes the homeless population and homeless service agencies.
  • Cities should provide hygiene facilities (port-a-potties, hand-washing stations) and trash pickup for residents of encampments – during and after any pandemic has passed.
  • There should be a moratorium on encampment sweeps that displace already displaced households and that often cause the loss of personal property that includes medication and other life-sustaining items.
  • All tests, treatment and quarantine locations should be offered without cost for all members of the community – housed or not, with or without health insurance.
  • Each community should identify space that those who do not have a permanent home can access in case of quarantine. Any costs should come out of community-level public health resources.
  • Federally, we would discourage homeless dollars being used to provide quarantine, testing or treatment. Homeless services are already woefully underfunded, and widespread homelessness was ALREADY a public health emergency!
  • Finally, we are concerned for the safety of unhoused folks who may be discharged from medical care to make room for COVID-19 treatment. This has happened in other emergency settings.  

If you are:

  • Experiencing symptoms? Please go to your nearest hospital or healthcare facility. Click here to find your closes Healthcare for the Homeless clinic. 
  • A service agency administering to vulnerable folks? Click here for CDC Posters to post in public areas about the spread of COVID-19, and see the additional resources below. 
  • An outreach worker or concerned citizen, consider stocking up on bottles of hand sanitizer or wipes to hand out to folks staying in encampments or other outdoor locations. 

Resources: