DCFPI Recommendations To the D.C. Council On The Homeless Services Reform Act

Today, the D.C. Council is holding a hearing on the proposed Homeless Services Reform Act, which will put in place new policies to help families in need of housing.  DCFPI strongly supports the Department of Human Services (DHS) goals of preventing families from becoming homeless, moving families out of shelter and into housing as quickly as possible, and providing shelter year-round to families in need.  However, the impact some provisions in the act would have on homeless families and individuals raises concerns.

DCFPI policy analyst Kate Coventry presented recommendations on four sections of the Homeless Services Reform Act today. Here is her testimony:

Provisional Placement of Families

The proposed legislation would establish a 14-day period of provisional eligibility for families seeking shelter, in part to give DHS time to work with families to seek alternatives to entering shelter.  DCFPI shares DHS’s goal of identifying alternatives to shelter for families when possible and recognizes that identifying potential alternatives may take a number of days.  We have several suggestions to ensure that provisional placement is structured in a way that meets families’ needs and that protects families from being terminated from shelter in error.

The District must ensure that provisional eligibility causes as little disruption to the family as possible.  Parents need to be able to attend work or training and get their kids to school without worrying that these activities are interfering with their shelter applications.  That is not what happened this past winter, when some families were given shelter “respite stays.”  These families were guaranteed shelter for just one night at a time.  Each morning, the family had to pack up all of their belongings and report to the Virginia Williams Center.  Families spent entire days either waiting at the Center or gathering paperwork.  Not surprisingly, this process made it difficult, if not impossible, to perform needed tasks such as getting kids to school or attending work preparation activities.  At least one mother was investigated by the Child and Family Services Agency because her child was truant during this period.  Provisional placement should be structured to avoid these problems.

Additionally, DCFPI believes that families should be allowed to remain in shelter during an appeal of shelter termination.  Recognizing that decisions about shelter eligibility may be made in error, families currently have the right to remain in shelter while they appeal termination decisions.  This ensures that the family has a safe place to sleep while the decision is reviewed.  Changing this policy means a family who is wrongfully denied shelter may be forced to sleep in unsafe conditions for weeks awaiting an appeal decision.  DCFPI strongly recommends that this provision be dropped from the bill.

Finally, the process for determining whether suitable alternative housing is available — particularly whether a family can stay with friends or family in the community — must be improved.  Homeless families report stories of hosts being under the impression that the stay was for just one night or one week.  Or they find that the individual who consented to house the homeless family had not consulted with the other adults in their household to secure their permission.  Or the potential host has discovered from reading their lease that they are at risk of eviction for hosting another family.  To prevent this from happening in the future, the Virginia Williams caseworker, homeless parent, and adults in the hosting household should have a meeting, in person or by phone, to clarify the length of time the family can stay, the terms of the host household’s lease and the responsibilities of each party.  Otherwise, community placements will lead to a revolving door, threatening the family’s ability to stabilize.

Defining Rapid Re-housing Placement as Per Se Appropriate

DCFPI supports the use of Rapid Re-Housing as a tool for moving families out of shelter as quickly as possible.  We recommend some changes to ensure that Rapid Re-housing serves as an important element of DC’s homeless services system that protects the needs and rights of homeless residents.

Current law allows providers to terminate a shelter resident if the resident turn down two offers of appropriate housing.  Residents have the right to appeal termination if the housing was not appropriate for their needs, such as lacking wheelchair accessibility or being located near their abuser.  The proposed HSRA changes would define a Rapid Re-housing placement as per se appropriate housing, which would mean that residents would lose their rights to appeal a placement based on factors that would be grounds for appeal of any other housing placement.  The proposed legislation should establish a family’s right to appeal a Rapid Re-housing placement.

Beyond that, there a number of issues that should be resolved before families are compelled to accept Rapid Re-Housing placements.  The regulations for this program are not finalized and thus the District has not defined which populations are appropriate and eligible for the program.  Additionally, the District has not determined what assistance will be offered to families who despite their best efforts are unable to maintain their housing after the Rapid re-housing subsidy period ends.  At the very least, families must have a year-round right to shelter to ensure they have a safe place to stay if they are unable to maintain their housing.  It is understandable that families would refuse Rapid Re-housing placements if they do not think they will be able to afford the apartment on their own and might have to wait until hypothermia to access shelter.

Mandatory Escrow

DCFPI agrees with DHS’s goals of helping residents accumulate assets and exit shelter successfully.  We have several recommendations for modifying the escrow proposal to ensure that it matches a family’s ability to save.

Current law requires homeless service providers to offer escrow but few providers do.  We believe a first step toward the goal of improving savings would be to enforce the requirement on providers to offer escrow.  This would allow the District to evaluate the effectiveness of a voluntary escrow program and measure the associated costs for both providers and the District government.

 Additionally, we believe that escrow programs should be voluntary, include incentives for saving, and should exclude the lowest income residents.  The DC Housing Authority recognizes that some families have income so low that they would be unable to pay rent and meet their basic needs, so these families pay no rent.  Other jurisdictions also recognize this.  New York City only requires individuals with earned income, not those that receive only TANF or SSI payments, to contribute to escrow.  Massachusetts requires a mandatory contribution of $150 per month from their TANF families who are in shelter, but their TANF benefits are much more generous than the District’s, $618 per month for a family of three compared to $428 per month.  After paying escrow, Massachusetts families have more in remaining benefits than District families have to start with.  With more than 70 percent of DC General Shelter families receiving public benefits as their only income, the majority of families will not be able to pay escrow and pay for necessities.

 If the intention is to encourage savings and good financial management, DCFPI suggests implementing a matched savings program along with financial literacy classes as programs in Toronto (Canada), San Mateo County (California), and New York City do.  Programs like this that encourage savings without taking away from the every limited resources families have to meet their ongoing needs make the most sense.

 Changes to the Permanent Supportive Housing Program (PSH)

DCFPI supports DHS’s goals to save money and place new clients in the program.  We question, though, whether the proposed changes will create true savings or simply move costs to other District agencies.  PSH serves chronically homeless persons, those who are by definition at high risk of hospitalization or incarceration.  PSH provides the supportive services and stable housing that these persons need to address their problems.  If individuals lose these services while hospitalized or incarcerated, they will become dependent on more costly emergency services upon their release.  And these services can do little to help an individual re-stabilize.  DCFPI recommends that PSH clients retain access to supportive services during periods of institutionalization and upon release.  If the client is absent for an extended period of time and the subsidy is reassigned to another client, the institutionalized client should be put at the top of the waitlist for subsidies.  This will allow DHS to avoid paying rent on unused units and ensures that PSH residents can re-stabilize after institutionalization.

In closing, DCFPI hopes to work collaboratively with this Committee, DHS, and other stakeholders to improve these amendments to reach the goals of preventing families from becoming homeless, moving families out of shelter and into housing as quickly as possible, and providing shelter year-round to families in need.