Chairperson Bonds and members of the Committee, thank you for the opportunity to testify today. My name is Kate Coventry, and I am a senior policy analyst at the DC Fiscal Policy Institute. DCFPI is a nonprofit organization that promotes budget choices to reduce economic and racial inequality and build widespread prosperity in the District of Columbia through independent research and thoughtful policy recommendations.
I am here today to ask the DC Housing Authority (DCHA) to comply with the law and quickly issue new proposed regulations for locally-funded vouchers to allow applicants to self-certify their identity and to ensure that residents are not excluded from the program because of immigration status or involvement in the criminal justice system. Their proposed rules fail to do this, harming Black and Brown residents the most. I also urge DCHA to commit to the timely and regular release of core implementation metrics of all tenant vouchers so that stakeholders can monitor progress and better ensure that these investments are reaching residents as quickly as possible.
The fiscal year (FY) 2022 budget includes a historic investment in new tenant vouchers, yet it is taking DC residents 6.5 times the amount of time to lease up residents with locally-funded tenant vouchers compared to resident with federally-funded vouchers through the Emergency Housing Voucher (EHV) program. This is likely due to residents’ ability to self-certify in EHV but not in the local program, despite budget changes mandating DCHA to offer that option for locally-funded vouchers.
Recognizing the need to both process more vouchers and to house residents as quickly as possible, the Council included two new requirements in the Fiscal Year 2022 Budget Support Act of 2021 (BSA). It required DCHA to “promulgate emergency and final rules for tenant-based voucher assistance” establishing “a process to allow applicants to self-certify eligibility factors when an applicant cannot easily obtain verification documentation.” The BSA also requires DCHA to waive or modify rules, regulations, policies, and procedures so as not to exclude households from locally-funded tenant vouchers because of immigration status, prior criminal convictions, or pending criminal matters. Unfortunately, DCHA proposed rules issued on December 17, 2021, fall short on both of these issues, meaning they are not complying with local law.
DCFPI urges DCHA to issue new emergency regulations that address these issues. If DCHA does not act, the Council should amend the Local Rent Supplement Program statute.
DCHA’s Failure to Comply with Local Law Ignores Evidence on Effectiveness of EHV’s Self-Certification Process
In the American Rescue Plan Act, the federal government allocated EHVs to the District. The federal government wanted localities to lease these vouchers up as quickly as possible, so they reduced some of the known barriers that cause delays. Particularly, the federal government allowed applicants to self-certify their identity rather than requiring a photo identification (ID). Photo IDs are difficult and time consuming to obtain, particularly because an applicant must have a birth certificate. Both IDs and birth certificates are easy to lose when a resident is homeless and lacks a safe place to store them. Also, each jurisdiction has their own process for obtaining a birth certificate and sets their own fees. Clients and homeless service providers have reported waits of up to a year or more. One provider had a client who waited for three years. And some jurisdictions limit the number of birth certificates a person can receive.
Self-certification can lead to much quicker lease ups, based on evidence from the EHV process. The average number of days from an EHV client being assigned to a provider and an application being completed is 19 days, compared to 126 days for locally-funded PSH clients, data from the Single Adult System (SAS) Dashboard show. We urge DCHA to release new regulations that accept self-certification for locally-funded vouchers.
DCHA’s Failure to Comply with Local Law is Harming Black and Brown Residents the Most
DCHA’s proposed regulations also fail to “waive or modify… rules, regulations, policies, and procedures so as not to exclude households on the basis of immigration status, prior criminal convictions, or pending criminal matters.” By not changing their policies around immigration, prior criminal convictions, and pending criminal matters, DCHA is excluding many residents who desperately need affordable housing. And the excluded residents are overwhelmingly Black and Brown.
Returning citizens are overwhelmingly Black because of systemic racism and discriminatory policing, both of which lead to huge racial disparities in police interactions, arrest, and sentencing. As the Sentencing Project reports, “Black and White Americans encounter the police at different rates and for different reasons, and they are treated differently during these encounters” This is because of both officer discretion and formal policies. For example, using discretion, officers are more likely to stop Black drivers and, once stopped, more likely to search Black drivers. And formal “stop and frisk” policies in which officers search individuals for contraband, are largely implemented in Black neighborhoods against Black residents. Data from the Metropolitan Police Department shows that 70 percent of stops and over 90 percent of frisks were of Black people.
We urge DCHA to issue new regulations that do not exclude residents because of immigration status, prior criminal convictions, and pending criminal matters.
DCHA Should Regularly Provide Data so Stakeholders Can Monitor Progress
Given the historic investments in vouchers in the FY 2022 budget, it is crucial for the DC Council and other stakeholders to monitor their implementation. DHS and DCHA promised that they would regularly provide data through a public-facing Voucher Tracker, but this tracker has not been launched yet. As presented to the DC Interagency Council on Homelessness (ICH) Single Adult System Work Group, this Tracker is supposed to include:
- the total number of FY 2022 vouchers by type;
- how many are available;
- how many are matched to a client;
- how many are pending with DCHA;
- how many voucher applications have been approved; and,
- how many have been housed.
The tracker is also supposed to document the voucher timeline, including the:
- time between matching a client to a voucher and their submission of the application;
- time between the submission of the application and DCHA approval of the application;
- time between DCHA approval of the application and lease up of the apartment; and,
- total time from the match to lease up.
Finally, the tracker is supposed to document housing resources by population (individuals vs families), including:
- available DHS resources by type;
- number of residents who qualify; and,
- percentage of those residents who will be matched.
We are asking DCHA a launch this tracker as soon as possible.
DCHA should work with DHS to launch a real-time dashboard accessible to the Council, DC ICH stakeholders, and providers who are part of the program expansion. This dashboard should include more information than in the Voucher Tracker in order to help these stakeholders pinpoint problems and bottlenecks. Each major step of the process should be listed in the dashboard. At a minimum, the dashboard should include the number who:
- have all the required documents readily available;
- are missing documents according to the DCHA system;
- have identified a unit to rent;
- are waiting for a unit inspection by DCHA; and,
- are waiting for DCHA’s approval for their application.
The dashboard should also document the average amount of time spent at each step. DHS and DCHA should also create target outcomes by month for the number to have achieved each step as well as create target outcomes for length of time each household spends at each step. The agencies should submit a monthly written report on data and outcomes should be submitted to the Committee on Human Services and the DC ICH for their review and input.
The dashboard should also document the racial and gender breakdown of those receiving resources to ensure equity in the distribution of vouchers.
DCFPI envisions a future where no one is homeless for a long time and no one dies without the dignity of a home. The FY 2022 budget will bring us much closer to this goal but only if we ensure timely implementation of the resources and commit to greater transparency.
Thank you for the opportunity to testify, and I’m happy to answer any questions.
 Proposed Regulations Title 14 DCMR Chapter 95 “Rent Subsidy Programs: Local Rent Supplement Program” Published in the DC Register on December 17, 2021.
 Reported by Mirim’s Kitchen and Washington Legal Clinic for the Homeless.
 Reported by Foundry United Methodist Church.
 Reported by Miriam’s Kitchen, Foundry United Methodist Church, and Washington Legal Clinic for the Homeless.
 Interagency Council on Homelessness Executive Committee Power point Presentation. January 11, 2022.
 The Sentencing Project (2015) Black Lives Matter: Eliminating Racial Inequity in the Criminal Justice System” https://www.sentencingproject.org/publications/black-lives-matter-eliminating-racial-inequity-in-the-criminal-justice-system/
 Interagency Council on Homelessness Single Adults Work Group Power point Presentation. November 2, 2021.