Members of the Board, 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). 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 you to reject the proposed regulations for locally-funded vouchers or amend them 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. The proposed rules fail to do this, harming Black and Brown residents the most.
The fiscal year (FY) 2022 budget includes a historic investment in new tenant vouchers, yet it is taking DC 6.5 times the amount of time to lease up residents with locally-funded tenant vouchers compared to residents 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 the DC Housing Authority (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 FY 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’s proposed rules fall short on both issues, meaning they are not complying with local law.
DCFPI urges the Board to reject these proposed regulations or amend them to address these issues.
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. 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. Some of these clients had photocopies of their identification but not the originals. And some jurisdictions limit the number of birth certificates a person can receive, meaning a client will never be able to get a birth certificate.
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 Permanent Supportive Housing (PSH) clients, data from the Single Adult System (SAS) Dashboard show. The proposed regulations allow for initial recertification but require identification before the client can lease up. We urge the Board to reject these proposed regulations or amend them to allow self-certification without requiring identification before the client can lease up.
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 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 the Board to reject these proposed regulations or amend them to not exclude residents because of immigration status, prior criminal convictions, and pending criminal matters.
 “Resolution 22-09: To Adopt Emergency Regulations to Allow Self-Certification of Eligibility Factors under the Tenant-Based Assistance under Local Rent Supplement Program” Accessed February 8, 2022.
 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/