UHHP Weighs in on New Homeless Housing Regulations

UHHP member organizations are invited to support a letter recently sent to the Secretary of the U.S. Dept. of Housing & Urban Development outlining ideas for the new HEARTH Act regulations, which are currently in development.  The letter can be used as an example or cited in a letter to HUD supporting the UHHP positions.

The UHHP Policy & Advocacy Committee developed the letter after a review of the regulations and thoughtful discussions about ways to improve the current program.  This committee has more than thirty members and represents the broad cross-section of UHHP membership.

Specific suggestions in the letter include:

1. Definition of homelessness (Amended Section 103 of McKinney-Vento Act), including clarification for “temporarily residing in an institutional setting” (Paragraph 103(a)(4)) and “persistent housing instability”(Section 103(a)(6);
2. Other definitions, including at risk of homelessness (Amended Section 401(1)), coordination of services (Amended Section 401(13)(C) of the McKinney Act), and outpatient health services (Amended Section 401(14));
3. Preventing involuntary family separation (New Section 404(b) of McKinney-Vento Act);
4. Reimbursement for leasing of property or portions of property (Amended Section 423(a)(3) of the McKinney-Vento Act);
5. Eligibility for permanent housing (New Section 423(f) of McKinney-Vento Act);
6. Program requirements (Amended Section 426(b) of McKinney-Vento Act); and
7. Funding formula (New Section 427(b)(2)(B)(i) of McKinney-Vento Act)

The UHHP Policy Committee will next tackle recommendations for a new funding formula that better serves the Los Angeles region.  The recent letter notes:

The current formula fails to consider the number of people experiencing homelessness in relevant geographic regions and therefore neglects need as a basic element of the grant award. The formula also favors communities with an aging housing stock, even though this condition has not been linked to the incidence of homelessness. Newer housing stock does not make housing in any community more available or affordable to people who are homeless or at risk of homelessness. As a result, the formula disadvantages jurisdictions with large homeless populations and unavailable or unaffordable housing stock, even though research demonstrates (and the HEARTH Act finds) the lack of available affordable housing to be the largest contributor to homelessness in any community.

The current formula significantly disadvantages the Los Angeles Continuum of Care, the jurisdiction with the largest homeless population in the country. Though the Los Angeles Homeless Services Authority’s Continuum encompassed a geographic area of over nine million people and a homeless population of over 68,000 during the period preceding the 2009 grant award, our Continuum received only $8.09 per capita and $1,078 per homeless person from the 2008 grant award, significantly less than other large cities such as New York ($11.10 per capita/$1,824 per homeless resident), San Francisco ($27.20 per capita/$3,649 per homeless resident), Boston ($35.95 per capita/$4,224 per homeless resident), and Chicago ($18.20 per capita/$8,637 per homeless resident).