Testimony of Kate Coventry, At the Public Hearing on the Consolidated Plan Proposed Substantial Amendment FY 2015 HOME Tenant Based Rental Assistant (TBRA)

Director Kelly, thank you for the opportunity to testify today. My name is Kate Coventry, and I am a policy analyst with the DC Fiscal Policy Institute. DCFPI engages in research and public education on the fiscal and economic health of the District of Columbia, with a particular emphasis on how policies impact low-and-moderate income families. I am also a voting member of the District’s Interagency Council on Homelessness (ICH).

I am here today to testify on the Proposed Substantial Amendment to the District’s FY11 — FY15 Consolidated Plan to reprogram $3 million of HOME funds received from the U.S. Department of Housing and Urban Development (HUD) to provide Tenant Based Rental Assistance (TBRA) to homeless households, through the Department of Human Services (DHS). DCFPI would like to both offer recommendations as well as ask the Department of Housing and Community Development (DHCD) to provide clarity around the following issues so that the public can fully understand and evaluate this proposed amendment.

Clarify the Need for Individuals

The proposed amendment states that TBRA will be used for both homeless individuals and families but the vast majority of need data presented represents only families. The ICH and the coordinated entry process have clearly documented the need for 1,500 additional permanent supportive housing (PSH) slots and 2,000 Rapid Re-housing (RRH) slots for homeless individuals. Available RRH funding will only serve 150 individuals. No new funding has been allocated to PSH for individuals who are not veterans this fiscal year. Their need is particularly critical as they suffer from serious illnesses that are difficult to manage effectively while homeless. They die young from diseases that could have been managed or prevented if they were housed. DCFPI urges DHCD to update the proposed amendment to reflect this need and to ensure that some TBRA is allocated to meet the needs of individuals.

How the District Will Utilized the Local Funds Allocated for PSH for Families

The fiscal year 2015 budget includes $2.3 million in local funding to create approximately 77 new PSH slots for families entering shelter in FY 2015. These slots are more than sufficient to meet the ICH’s projected need of PSH slots for 68 families.[1] Thus it is not clear why the District needs to use TBRA to serve families in need of PSH. It would be helpful if DHCD would provide clarification.

How Resources Will Be Divided Between Homeless Individuals and Families

The proposed amendment reports that the TBRA “will provide rental assistance to homeless households, as referred through coordinated entry.” As the District has separate coordinated entry systems for families and individuals, each with its own assessment tool and process of prioritizing residents for services, it is not clear how resources would be spread across the two systems. It would be helpful if the District would clarify if it intends to assign a particular amount of TBRA to each system and if so, how much it intends to assign to each, particularly as many more individuals are in need of assistance than families. Or if DHS plans to create a new single, unified priority list, it would be helpful if DHS would outline how it plans to do this, particularly as the two assessment tools use different scoring scales making it difficult to compare the vulnerability of a family versus an individual adult.  

How the District’s New Overflow Shelter Contracts Affect this Amendment

The proposed amendment reports that the District is proposing to use the TBRA funds to serve families in shelter in part to transition households out of shelter units and into housing to increase the number of family shelter units available for hypothermia placements. Since the drafting of this amendment, the District has contracted for an additional 240 units of family hypothermia shelter. It appears unnecessary to prioritize funds to increase the number of hypothermia shelter units available. Will DHCD make adjustments to the proposed amendment in light of these contracts?

Program Designs and Implementation Timeline

The Proposed Amendment appears to include three distinct programs:

  • a PSH-like program for families who will later enter built PSH units;
  • a program with more intensive services for families with high RRH scores, indicating the need for a high level of RRH support; and
  • a shallow subsidy program for families working 35 hours or more.

 It would be helpful if the Proposed Amendment outlined whether each program was to be administered with an existing program or would require the development of a new program model and governing regulations. It would help to know how each program was going to be administered, including who was responsible for paying rental assistance and providing services. At points the document refers to DHS providing services, but it is not clear if this means providing directly or contracting out. It would also be helpful to know the targeted lengths of assistance and intended outcomes for each program.

DCFPI has particular concerns about the PSH-like program. The proposed amendment reports that service providers will work with households to address barriers that prevent the household from qualifying for PSH (e.g. – credit, rental history, employment, and housing stability). Taking cues from HUD and national research, the District is moving towards a PSH system that uses a Housing First model, with low barriers to entry. This will allow high need individuals, the very people who need PSH the most, to be served. Rather than using TBRA to try to change the individuals in need, the District needs to rework the programs so that they can meet the needs of the individuals who need the program the most.

DCFPI also has concerns about creating a transitional-like program to prepare families to be “housing-ready”. The District, like much of the nation is moving towards a “housing first” approach because transitional housing programs have not been found to be as effective at moving residents into permanent housing as “housing first” programs like permanent supportive housing. Yet, the program DC is creating sounds very similar to transitional housing, an intervention the ICH will be reducing in the Strategic Plan in favor of these more successful models like PSH and RRH. It is clear from national research and direction from HUD that communities should be decreasing, not increasing our transitional housing programs.

Coordinating the Proposed Amendment with the ICH Strategic Planning Effort

The ICH is currently working to develop a new Strategic Plan to outline how the District will tackle homelessness over the next five years. With HUD-funded technical assistance, the ICH is identifying the number and type of housing intervention needed for both homeless families and individuals. Additionally, the ICH is developing requirements for each type of housing intervention, so that homeless residents receive consistent services across provider and funding source. It is not clear how the programs outlined in the proposal amendment coordinate with existing interventions. If the Proposed Amendment has not been coordinated with these efforts, DCFPI recommends that DHCD work to do so now to ensure that this funding is meeting an identified need and that program design is consistent with the District’s other efforts.

Funding Disbursement Process

DCFPI asks DHCD to clarify the process for disbursing this funding, such as whether this funding will be awarded via competition or through existing contracts, as this will greatly affect the timeline. It seems unlikely that these funds could be awarded via competition in sufficient time to create hypothermia shelter capacity, one of the stated goals of the proposed amendment.

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

[1] The ICH Winter Plan anticipates 840 families will enter shelter during FY 2015 hypothermia. F-SPDAT assessments have found that approximately 8 percent of families entering shelter will score for PSH.