Testimony delivered on February 26, 2026

Chairperson Frumin and members of the Committee, thank you for the opportunity to testify today. My name is Mychal Cohen, and I am the Senior Housing Policy Analyst at the DC Fiscal Policy Institute (DCFPI). DCFPI is a non-profit organization that shapes racially-just tax, budget, and policy decisions by centering Black and brown communities in our research and analysis, community partnerships, and advocacy efforts to advance an antiracist, equitable future.

Many DC households are facing housing instability and the programs meant to keep them stable are failing. The numbers of District residents paying substantial amounts of their income in rent is unacceptably high and that burden falls disproportionately on Black and brown residents. From 2019 to 2023, more than 1 in 4 Black renters (29.9 percent) and 1 in 5 Hispanic renters (20.1 percent) were extremely rent burdened, meaning they paid over 50 percent of their income in rent.^[1] These high rates of rent burden are contributing to the rise in evictions in the District. Analysis by New America found that completed evictions–2,031 in fiscal year (FY) 2025–were projected to surpass pre-pandemic levels, and eviction filings, while not at pre-pandemic levels, have risen steadily since the eviction moratorium of 2020.^[2],[3]

While the Emergency Rental Assistance Program (ERAP) should provide support to residents facing housing instability, the mayor and DC Council have underfunded ERAP and made drastic changes to the eligibility of the program. ERAP funding has steadily decreased since the pandemic and last year the Council passed the “Emergency Rental Assistance Reform Amendment Act of 2025.” This legislation narrowed the definition of a qualifying emergency, limited the ability of applicants to self-certify, and limited eligibility only to cases where the full arrears would be covered by ERAP funds. These changes make it more difficult for vulnerable households to qualify for assistance and thus put more households at risk for eviction. The Department of Human Services (DHS) also implemented a harmful, inaccessible, and exclusionary rollout of an in-person appointment and application process, evidence of an overall approach that does not invite community input.

The Council has debated how ERAP should be used. Chairperson Frumin has affirmed that ERAP should be for emergencies and not to “delay evictions for families for whom rent is chronically unaffordable.”^[4] But rather than sufficiently funding proactive alternatives for these households, such as long term housing vouchers or DC Flex, a shallow subsidy program that provides financial assistance to bridge the gap between income and rent, the Council narrowed eligibility and funding for ERAP. The Council should instead:

• Develop a comprehensive strategy for housing stability and eviction prevention in the District;
• Hold DHS accountable for the lack of clarity and community engagement in their implementation of ERAP;
• Reduce barriers to accessing emergency rental assistance for DC’s most vulnerable residents; and
• Collect and publish data on ERAP implementation to improve transparency and access.

Due to Underfunding, ERAP Fails to Meet the Needs of DC Residents With Low Incomes

Yearly cuts to funding for emergency rental assistance have accompanied yearly increases in completed evictions. Mayor Bowser initially proposed a $5 million budget in FY 2026 and the Council allocated an additional $3.6 million.^[5] But recognizing the inadequacy of this budget, the Council added a provision that directed $2.95 million of FY 2025 revenue growth to the program, as long as the additional revenues exceed actual expenditures, as estimated by the Chief Financial Officer (CFO).^[6] In December, the CFO certified the additional revenue was available and District leaders are now considering whether to implement this budget increase.^{[7], [8]}

Even if the contingent revenue is added, the ERAP budget is funded at its lowest level since the pandemic.^[9][10] And this funding is significantly less than the need, which the Urban Institute estimated at $76-108 million in 2024.^[11] While the District is facing budget challenges due to federal intervention, increasing costs, and declining revenues, ignoring the need for rental assistance will only lead to more evictions and their accompanying harms. The rise in evictions and homelessness will show up in other costs within our housing system while contributing to distress and displacement of residents who experience these traumas.

DHS’s Poor Implementation of ERAP Has Harmed Vulnerable Residents

DC Council must hold DHS accountable for ERAP implementation. The agency should be required to meaningfully engage with the community and reduce application barriers. In 2025, without any substantial community input, DHS shifted to an in-person process for scheduling ERAP appointments that left residents standing for hours in the cold and hindered access for residents unable to show up in person.^[12] They claimed that this change was in part to “better manage limited program funding, but the budget for administration increased from 10 percent of the total budget in FY 2025 to 15 percent in FY 2026.^[13] Any open dialogue with residents, providers, and advocates would have immediately raised questions about increased administrative costs in a year with less available funding and about accessibility issues for people with disabilities, working individuals, and elderly people.

The “Emergency Rental Assistance Reform Amendment Act of 2025” became law in July 2025, more than six months ago, but DHS has not released formal rulemaking for how it should be implemented.^[14] Without formal regulations, ERAP providers are left to interpret guidance on their own. This has led to discrepancies between providers in how they interpret requirements for documentation and acceptable emergencies. This process increases confusion and uncertainty among applicants. As DHS develops its formal regulations, it should be proactive about seeking input from residents who have used the program and the providers that help administer it.

A Lack of Data and Transparency Makes it Impossible to Understand Impact of ERAP changes

The 2025 changes to ERAP were passed without consideration of the impact on low-income households and ignoring evidence of disproportionate harm on Black and brown residents.^[15] The Council Office of Racial Equity found that a number of the provisions, such as the heightened documentation requirements, would likely harm Black and brown residents, and that provisions such as the narrowing definition of an “emergency” did not have enough evidence to inform racial equity impact.^[16] These provisions were based on unsubstantiated claims that could have been informed with additional data collection and transparency on the part of DHS. For instance, landlords, DC Council, and DHS made claims regarding potential fraud occurring within the program due to self-certification, but DHS did not actually track self-certification and could not provide evidence of consistent fraud occurring.^[17]

Now that the bill has passed, the District should collect and share demographic and income data to better understand the impact of these changes. Anecdotal evidence suggests that the population able to qualify for ERAP has shifted away from households with the lowest incomes who are least likely to have documentation or proof of their emergency. DHS’s performance oversight responses do not provide any clarity on potential demographic shifts among the population applying to ERAP.^[18] Such data will be critical to understanding the racial equity impact of the legislative and implementation changes. DHS does not update data that is critical for residents, analysts, and providers to make informed decisions. While data such as remaining funding and application denial reasons and rate are provided in the performance oversight responses, implementation of publicly available data on ERAP availability and process should be easily accessible and routinely updated.

ERAP can and should be a critical part of the District’s response to housing instability. Residents, advocates, providers, and DHS all have the same goal of ensuring stability and security for District households. With better data, open communication, clear and accessible guidelines, and funding sufficient to meet the need, DC can craft a well-function housing safety net for families at risk of eviction.

Thank you for the opportunity to testify, and I am happy to answer any questions.