Emergency Rental Assistance Program (ERAP)

The Emergency Rental Assistance Program (ERAP) is a new program created by the Federal government as part of the Consolidated Appropriations Act, 2021. This program is administered by the U.S. Treasury Department and provides Federal money to State governments, U.S. Territories, and local governments with more than 200,000 residents. These State-level and Municipal governments then distribute the money they received from the Federal government to individual households and landlords, usually using the money they received to fund already existing housing programs. Both renters and landlords can apply for ERAP funds but they cannot receive funds directly from the Federal government, they must go through State and Municipal government offices and programs. 

Since the passage of the American Rescue Plan in 2021, ERAP has undergone several important changes, although there are still many similarities between the two versions. One of the most significant changes has been that a household can now receive 18 months of assistance in total, whereas before it was only 12 months of benefits. 

While programs such as Residential Assistance for Families in Transition (RAFT) has an income eligibility limit of 50%, and 60% for victims of domestic violence, renters can apply for ERAP assistance if their income is up to 80% of Area Median Income (AMI). To qualify, renters must be at risk of homelessness or housing instability due to COVID-19. This instability can be due to unemployment, decreased wages, or increased expenses. Renters may receive assistance with rent and utilities that were accrued since March 13, 2020.  

In Massachusetts the specific qualifications to qualify for ERAP are: 

  • The applicant must be able to prove that you have faced financial hardship due to Covid-19. 
  • The renter household income must be at or below 80 percent of the area median income 
  • At least one or more individuals living in the household must qualify for unemployment or has experienced a reduction in household income, incurred significant costs, or experienced a financial hardship die to COVID-19 
  • The applicant can demonstrate a risk of experiencing homelessness or housing instability 

If you are in Massachusetts and looking to apply for this program or want more information you can click this link: https://www.mass.gov/info-details/emergency-housing-assistance-during-covid-19.

U.S. Department of the Treasury Press Release: https://home.treasury.gov/news/press-releases/sm1228

Information for landlords on emergency housing assistance: https://www.mass.gov/info-details/information-for-landlords-on-emergency-housing-assistance

Please email Director of Policy Benjamin Daly at bdaly@homesforfamilies.org with any questions, comments, or concerns!   

FY’22 Senate Budget

Senate Ways and Means releases FY’22 Budget  

On May 11, 2021, Chair of the Senate Ways and Means Committee Michael Rodrigues released the Senate’s proposed version of the State Budget for the fiscal year 2022. Find our full breakdown below!  

As a reminder, each year the Governor, the House Ways and Means Committee, and the Senate Ways and Means Committee put forward their own version of the budget for the following fiscal year. Following the announcement of the House and Senate Ways and Means Committees’ budget there is a short 2-3 day period during which amendments can be submitted. These amendments are often requests for specific changes in the language of the budget and/or are asking for an increase in funding for certain line items. These amendments are then reviewed privately by House and Senate leadership, who are largely responsible for determining whether or not these amendments are adopted. 

The following chart lays out the amendments that Homes for Families filed and supported for both the House and Senate budgets. Directly below we have provided a brief guide on understanding the acronyms you will find in the chart. 

FY’22 HFF Budget Requests: Fiscal Year 2022 Homes For Families Budget Requests 

HWM Amendments: House Ways and Means Amendments 

SWM Amendments: Senate Ways and Means Amendments 

EA: Emergency Assistance  

MRVP: Massachusetts Rental Voucher Program  

RAFT: Residential Assistance for Families in Transition  

HomeBASE: Massachusetts’ re-housing benefit  


Similar to the House Budget, we at Homes for Families feel that the Senate budget misses the moment and underfunds key homelessness prevention programs. With economic inequalities exacerbated by the pandemic, now more than ever our State government must take an active role in helping those who need it most. We were particularly disappointed to see that funding for MRVP did not increase to the 160 million we were hoping for.

Below is a summary of the amendments that Homes for Families worked to support on the Senate side: 

  • Amendment #804: Improves EA data collection. This includes reports on the race and ethnicity of families who have applied for services, were given/denied assistance, reasons for homelessness, the type of assistance required, and the number of days between the application submission and the approval. (Adopted)  
  • Amendment #444: Increases MRVP funding to $160,000,000 from $129,981,667. (Rejected)  
  • Amendment #835: Allows eligible families to receive the maximum amounts for both RAFT and HomeBASE, without a $10,000 combined sum restriction. This amendment allows eligible HomeBASE participants to receive housing assistance of up to $10,000 to prevent eviction or relocation, without needing to be evicted first. It also calls for improving data collection on race and ethnicity on families receiving assistance and those denied assistance. The budget was suggested to increase to $45,000,000. (Rejected)  
  • Amendment #756: Extends the financial assistance provided by RAFT past the termination of the state of emergency concerning COVID-19. Up to $10,000 in rental, mortgage, and utilities assistance, in any 12-month period, will be extended to December 21, 2021. This is provided that financial assistance will not exceed $7000 from January 1, 2022 to June 30, 2022. (Adopted)  

The next step of the budget process – and the final step before it is sent to the Governor for a final signature – is the Conference Committee, during which selected members of the House and the Senate reconcile the differences between the two budgets. Homes for Families will be working to make sure that the best language from each budget is reflected in the final budget. We will be in touch in the coming weeks about how you can help with this effort!
 
Please email our Director of Policy Benjamin Daly at bdaly@homesforfamilies.org with any questions, comments, or concerns! 

House Ways and Means releases FY’22 Budget

The House Ways and Means Fiscal Year 2022 State Budget was released on Wednesday, April 14th, and we have a full report for you!

To recap, each year the Governor, House Ways and Means Committee, and Senate Ways and Means Committee propose a budget for the following fiscal year. After both the House and Senate Ways and Means Committees release their budgets, there is a short time during which amendments can be filed to alter certain line items and increase funding. These amendments are then considered by House and Senate Leadership respectively, who determine which amendments make it into the final budget. The House released their budget this past Wednesday, and we at HFF have been hard at work filing amendments and making sure we are fighting for increased funding for critical programs related to family homelessness before next Monday’s deadline. For the full breakdown of how the House budget is different from the Governor’s Budget, and the funding from prior years, see the table below:

Line ItemProgramFY’20 FundingFY’21 FundingFY’22 HFF Budget RequestsGovernor’s FY’22 ProposalHouse FY’22 Proposal
7004-9316RAFT21,000,00054,700,00055,000,00025,970,61222,000,000
7004-0101EA171,000,000180,000,000196,000,000195,000,000195,900,000
7004-9024MRVP116,000,000135,000,000160,000,000122,645,860128,400,000 plus 20 Million unspent in FY’21
7004-0108HomeBASE25,825,00029,058,61845,000,00025,970,61225,900,000

As you can see, the House Budget is pretty much on par with the Governor’s recommendations, which fall short of meeting the moment we are in and the level of funding that is necessary. Overall, we feel as if this Budget fails to meet the moment, but we are optimistic that through our legislative and budgetary advocacy, we can get to where we need to be. HFF is advocating for several amendments, and we need your help to make sure there are as many House co-sponsors as possible before Monday’s deadline, when amendments are either allowed into the budget or disregarded.

Home For Families Amendment Priorities:

Amendment #668: To increase MRVP funding and to ensure families with MRVP vouchers pay no more than 30% of income towards rent. HFF worked alongside CHAPA to write the language for and file this amendment with Representative Madaro. The amendment would raise MRVP funding to $160 million, reduce the rent burden for families from 40% of income to 30%, and add essential reporting requirements to the program.

Amendment #486: To improve data collection, equity, and access for the Emergency Assistance family shelter program and to create an ombudsperson, sponsored by Representative Decker. The amendment would provide language for vital data collection around families in EA as well as the HomeBASE program. The creation of an ombudsperson in the Executive Office of Housing and Economic Development would serve as an advocate for EA and HomeBASE participants.  

Amendment #767: To improve access to IDs for people experiencing homelessness by eliminating the $25 fee and reducing the verification burden, sponsored by Representatives Khan and O’Day. This amendment would provide $75,000 for an initiative to provide standard MA IDs to individuals experiencing homelessness who lack valid MA IDs.

Amendment #447: To extend HomeBASE for families timing out of HomeBASE who would otherwise return to homelessness, and to improve data collection on HomeBASE participants, sponsored by Representative Barber. This amendment seeks to allow families participating in HomeBASE to continue receiving benefits if they are eligible and in good standing and otherwise at risk of experiencing homelessness again, as well as improving data collection on race and ethnicity.

WE NEED YOU TO TAKE ACTION by calling your State Representative and asking them to co-sponsor these amendments!

To look up your state Representative go here or here

SCRIPT:

“Hi, my name is _________________and I am calling/emailing from (_______city/town and shelter name if you want to share) to urge Representative___________________ to co-sponsor and advocate in support of the following key amendments in the House Ways and Means fiscal year 2022 state budget:

Amendment #668: To increase MRVP funding and to ensure families with MRVP vouchers pay no more than 30% of income towards rent. HFF worked alongside CHAPA to write the language for and file this amendment with Representative Madaro. The amendment would raise MRVP funding to $160 million, reduce the rent burden for families from 40% of income to 30%, and add essential reporting requirements to the program.

Amendment #486: To improve data collection, equity, and access for the Emergency Assistance family shelter program and to create an ombudsperson, sponsored by Representative Decker. The amendment would provide language for vital data collection around families in EA as well as the HomeBASE program. The creation of an ombudsperson in the Executive Office of Housing and Economic Development would serve as an advocate for EA and HomeBASE participants.  

Amendment #767: To improve access to IDs for people experiencing homelessness by eliminating the $25 fee and reducing the verification burden, sponsored by Representatives Khan and O’Day. This amendment would provide $75,000 for an initiative to provide standard MA IDs to individuals experiencing homelessness who lack valid MA IDs.

Amendment #447: To extend HomeBASE for families timing out of HomeBASE who would otherwise return to homelessness, and to improve data collection on HomeBASE participants, sponsored by Representative Barber. This amendment seeks to allow families participating in HomeBASE to continue receiving benefits if they are eligible and in good standing and otherwise at risk of experiencing homelessness again, as well as improving data collection on race and ethnicity.

Please Email bdaly@homesforfamiles.org with any questions, comments, concerns!

Update on DHCD’s efforts to curb family homelessness. (This is a good thing!)

Image

It’s time for another blog post on the regulation changes, which is a good thing! However, it’s not exactly an update because nothing has been decided upon or implemented, but for lack of a better word, here’s an update:

DHCD has reached out to housing authorities (good thing!), asking them to consider allowing people whose names are not on the lease (namely homeless families with children) to stay doubled up for longer than the leases permit.  This is a semi-step in the right direction seeing as though DHCD no longer considers those in doubled up living situations as eligible for assistance.  But let’s just take a moment and analyze the circumstances. As stated on the Boston Housing Authority Public Housing Lease, the “Resident agrees not to assign this lease, not to sublet or transfer possession of the Apartment, not to take in boarders or lodgers and not to use or permit the use of the Apartment for any purpose other than as a private dwelling solely for Resident and the individuals specifically listed on this lease or listed on asubsequent written Lease Addendum”.

So to be clear- no one can stay in these apartments unless their name is on the lease.  But if we, as a community, are expecting families to rely on each other in times of hardship rather than emergency assistance, this portion of the lease poses a problem to that expectation. (Not a good thing). Those who are expected to provide shelter are faced with a dilemma: They can either a) tell their friend or family member they legally cannot stay with them or b) risk facing eviction because they are breaking the lease and providing the shelter that we are expecting them to provide. Instead of curbing the number that enters the EA system, it may very well double.  (Definitely NOT a good thing).

DHCD asked the housing authorities, who are a natural partner in solving the current crisis, to help by giving “special consideration to families who are living temporarily doubled up in state public housing…[encouraging them] to give even greater consideration for longer periods of time…in doing so is likely to prevent homelessness”.  They leave this decision up to the housing authorities’ discretion, and have yet to change the HomeBASE rules to allow for lenience with doubling up.

But working with housing authorities is a good thing, keeping children in houses instead of cars is a good thing and getting creative with the ways we make sure families have shelter is a good thing.  Especially as the temperature is dropping and the first signs of winter are showing. Getting the community involved in addressing the current family homelessness crisis is crucial, and will allow for RAFT funds to be used more appropriately since they can potentially supplement additional utility costs with RAFT money. It may not be ideal and hopefully DHCD will do more to reach out to the greater community, but we are counting good things…and a semi-step in the right direction is one of them!

A Conversation With Leader Byron Rushing

We walked back into the Homes for Families office on air. We, being the interns at HFF, Gabe Weinreb, Janet Villafane and Jamie Minton. Libby and Michelle wouldn’t stop laughing at our big smiles and sparkling eyes, we must have looked like we just ran into our favorite celebrity.

Well, to be honest, we kind of did.

We just left the office of Leader Byron Rushing, majority whip. Leader Rushing generously agreed to meet with us so we could learn firsthand what inspired him to become the warrior of social justice we see today.  We sat in his waiting room with our minds full of questions and blank notebook. Floating back into the HFF office, our pads were filled with furiously scribbled notes and minds full of answers… and even more questions.  Here is our experience:

Leader Byron Rushing of the state legislature agreed to meet with me and the other interns yesterday.  We had a fascinating conversation about all sorts of things like deinstitutionalization, busing in Boston, and the shifting winds of social change throughout the last half century.  One remark Leader Rushing made struck me more than any other.  He said that the only difference between the working class and the middle class was that the working class was unionized.  The middle class works!  As leader Rushing put it, they believe in a set of myths that they use to elevate themselves above those whom they believe are less fortunate: that their children will go to college; that they will have a long, comfortable retirement; that their property is secure.  But everyday class is becoming less and less indicative of success as defined by these goals.  So why is “working class” a bad word?

-Gabe

Leader Rushing gave us his background, and spoke about how the Civil Rights movement wasn’t about the power of racism as much as it was about the power of power itself and politics. It wasn’t about black and whites being in the same schools, but the difference in the quality of education.

The biggest impact of change he mentioned was the fact that discriminated people realized they could do something. In my interpretation of what he said- One voice went viral and women stood up for their rights. The gays stood up for their rights. Discriminated people had a voice.

When we engaged in a conversation about homelessness, EBT and his five year plan he explained how the turn in the economy had inevitably took a toile on the five year plan, and that it was going to take time for the crisis to recover.  However, overall he believes in building more affordable housing; it was encouraging that someone in his position believed in what we believe.

At one point he said that some people find it hard to believe that there are people who are keeping the people poor. And that realistically there are people who simply do not like us. It’s not just ignorance or lack of knowledge, they simply do not like us and it’s hard to imagine that.

He gave an example of payday lenders. You find them in the city and they charge you so much to cash a check, but you don’t find that in the suburbs. I had read an article titled “Using the Poor as Piggy Banks”, which I shared with Leader Rushing. It was about court fees and child support, how that’s just another system that keeps you stuck. How can you expect more money from people who just don’t have it?

We discussed how many people do not share their experiences, but he convinced me that sharing stories is exactly what is going to make things happen. When one stands up, others get the courage to stand up, and that’s what Homes for Families does. We share the stories of families; we give them a voice- the more families act together, the louder we get. And we keep doing so until positive changes are made.

Leader Rushing was able to balance all aspects of politics and power, his background has given him strength and is what’s molded him into the caring, outgoing and wise person he is.

He truly does stand for what he believes in. That alone is honorable.

-Janet

Having the opportunity to meet Leader Rushing is…beyond description. Not only does it impress my classmates, but to meet with the majority whip for an hour solely to pick his brain? So exciting.

Being immersed in the family homeless community over the summer, I constantly hear the words: HOUSING FIRST.  It is the one thing that providers, families, advocates and evidently everyone agrees on.  In the words of Leader Rushing, “Fire the social workers and hire more carpenters”.  The point Leader Rushing and similar minded people are making is that people need a place to live before anything else.  Enough with the immediate psychoanalysis from those who have the power to put a roof over a family’s head; those steps, while necessary, should come second to ensuring families have a safe place to eat, sleep, and live.

Leader Rushing left us with more advice than I can list, but what struck me the most was wisdom that can only come from personal history, past experience and current accomplishments. Firstly, it is so important to tell your story.  It is the personal experience of millions of the Americans facing hardships that debunk stereotypes and illuminate the truth. Individual stories allow for those hardships to be acknowledged for the injustices that they are…whatever they may be, and changed at a national level.  We must tell our story.  The second piece of wisdom bestowed upon us was to call out the people who are keeping others poor.  Sometimes, it’s not always ignorance that drives ideology or anti-poverty rhetoric.  We have to acknowledge that and seek out the people, policies and practices that work against alleviating poverty and call them out. I look forward to doing so.

-Jamie

Just like all the movements that have come before us, those who understand the importance of fighting for social justice must band together. Only when enough people unite, will voices be loud enough to drown out the overplayed notion that poor people choose to be poor.  The momentum created by one voice is contagious and a condition we can only hope to catch.  The future of our country depends on it.

And So Can You.

At Visioning Day on August 8, 2012, I made a commitment.  I committed to blog about what I saw, heard and felt.  I made this commitment in front of about 150 people, so here I am, keeping it.

And what I saw, were families, shelters, and other stakeholders coming together to share their ideas as to improve the homelessness situation. 47% of them were people who have experienced homelessness. The people who know the problems firsthand and the people who had to find their own solutions. The people we should really, really listen to.

What I heard were voices of all kind, rising above stereotype and misinformation, and committing to vote, write their legislators, attend workshops, and do so much more than their sanctioned obligations.

What I felt…well here, you feel it yourself:

This year’s winner of the Inspiring Leader Award is Ivette Arroyo. I challenge you to read her speech, feel the goose bumps that I felt and allow the tears that rolled down so many people’s cheeks upon hearing these words to roll down yours.  I challenge you to take a deep breath after you finish and give it chance to feel real, because it is.  I challenge you to see this story of success as one of the rule and not just an exception, because it is.

My name is Ivette Arroyo.  I was in shelter for over 12 months in 2010- 2011.  I have been in a hotel shelter, two scattered sites, and a family shelter.

I am a mother of three girls 15, 13, 10 and an 8 year old boy.

My homelessness came after a struggle with Domestic Violence and deep depression.  One depression set in, I lost.  Little by little, I lost.

After losing my amazing job, I became more and more depressed.  Eventually I couldn’t get out of bed, couldn’t help my kids, or myself.  I lost it all, lost my babies, my home, everything.  I was left to start from a place I never thought I’d find myself. The middle of nowhere.  ROCK BOTTOM.

For a while I felt hopeless, but….because I am a woman and because I am a mother…I pushed through.

I got into shelter and I got counseling to deal with the trauma that came with DV, family separation and mental health issues.

As I began to heal, I was able to begin to participate in different workshops like self defense, advocacy, financial literacy, parenting.  I was also able to set some goals around going back to school and work.

I was offered an internship.  First I worked at Homes for Families, there I learned how the system worked and made sure I did what I could to promote advocacy with the families within the shelter system.

When that internship ended, a domestic violence shelter offered me a shot at an internship so I took it on.

Shortly after, I, Ivette Arroyo, was asked to join their staff. My work had been recognized and someone had noticed, an entire team had noticed!

A year ago today, I was an intern at Homes for Families working the registration table. I was proud of myself then because I had accomplished a lot.

I had risen significantly from rock bottom and was helping others.  But today?  Wow. Today I stand before you as someone who continues to rise. And not only do I rise but I am fortunate enough to have a job that allows me to help other women rise up!

My family now works every day through the reunification and healing process and I have been housed for about a year.  What else can I say other than- I am lucky to feel so inspired by life and opportunity and I’m happy that I can inspire you.

So- I accept this Inspiring Leadership Award and I ask you to acknowledge the struggles, but focus on the inspiration you find around you, children, family, clients, goals…whatever the inspiration may be…and push through.  Because if I can, so can you.

So can you.

So can you, what?

What can you do?

Make a commitment, and do it.

Don’t forget to share it too!

jmexox

DRAFT Analysis of DHCD’s proposed EA Eligibility regulation changes and some opinions and questions there of….

The family homelessness system in Massachusetts has been in crisis since….well, since before the system itself was created.  We all know that shelter is not a replacement for a home. And nobody feels that children be forced to sleep on the streets, in parks, in cars, in hospital waiting rooms, or in crowded and unsafe homes.  Yet, we all know the crisis has drastically escalated since the great recession.  We have close to 1,700 families in motels, 2,000 families in shelter and 6,000 in short term rental assistance through HomeBASE.  There is an average of 20 families that enter the system each day (based on DHCD entry data for the past 10 days).  We also know that for every family who enters shelter- one is turned away.  With stricter eligibility criteria more families are already being turned away, and even more will be turned away with the implementation of more restrictions. With inadequate re-housing resources and no more short term subsidies…less families will exit shelters and motels.  Is it time to sound the alarm? Is it time to wake up the general public to the reality and severity of the crisis?

Could the Administration declare a state of emergency? Surely a natural disaster affecting close to 10,000 families (comprised of approximately 29,000 men, women and children) would garner such a reaction.  Why not an economic disaster?

Should the Administration call on faith communities, schools, the business community, the federal government to help figure out how to keep families safe when there is not enough affordable housing or adequate wages for families to meet their basic survival and safety needs?

The Administration’s current plan is to restrict eligibility for shelter to certain narrow subcategories of homeless families.  RAFT will be an option for some of the families that will no longer be considered eligible for shelter.

With the restrictions imminent, unless the Governor and/or the Administration decide otherwise, many questions remain:

  • How many families are projected to fall into the “no longer eligible category”?
  • What are the options for those families, especially when flexible cash assistance is insufficient or not appropriate?
  • Are communities prepared to handle the consequences of restricted eligibility? Are community members, such as faith communities, hospitals, health centers, schools, hot lines and and daycares aware of the changes?
  • Do homeless and at risk parents know who to call, where to go, and appeal/re-application policies if their situation changes or fear for their children’s safety due to the lack of shelter?
  • Have the Department of Children and Families and the Department of Public Health developed plans to address increases in care, protection, and health risks?

At HFF, we are working to understand the new policies and who they will impact.  Below is a summary of the regulations as we understand them (or click here for a document version).  We encourage shelters and community based organizations to share with front line staff, partner organizations and others that interact with families facing homelessness.  Besides understanding the regulations to advise people correctly, concerns can and must be voiced to elected officials- including the Governor’s office and Legislators.  There are better and more responsible ways to address the crisis than simply shutting the doors.

DRAFT Analysis of DHCD’s proposed EA regulation changes

v      309.020 BASIC PROGRAM ELIGIBILITY

  • An applicant family must demonstrate residency as an element of basic eligibility.  Basic eligibility must be determined by DHCD before presumptive eligibilityis granted to an applicant family.  Family must be able to document:
    • ID of each family member
    • Relationship of each family member
    • Massachusetts residency

v      309.040 ELIGIBILITY

  • A household is eligible ONLY if the following conditions exist:
    • Domestic violence
      • Household is at risk of DV in current housing OR
      • Family fled DV and has not had access to safe, permanent housing since leaving the housing situation from which they fled.
  • Fire, flood or natural disaster due to no fault of the family.
  • No fault eviction due to:
    • Foreclosure.
    • Condemnation due to no fault of the applicant household (*note that removed from the regulations were eligibility due to violation of the State Sanitary Code and overcrowded living arrangements).
    • The conduct of a guest or former household member, of whom the applicant household had no control over – limited to situations where:

¨       there is domestic violence,

¨       the one causing the eviction was mentally ill or

¨       the conduct of a minor child with a CHINS order in place that the parent is in compliance with.

  • Nonpayment of rent only where there is a documented medical condition or disability or caused by a documented, no fault, loss of income (of at least 10% within the past 12 months).

¨       Only applies to market rate housing or any other housing where rent is NOT determined based on income caused by.

  • A family member with income leaves the household.
    • if the family is determined eligible, the absent HH member cannot be re-added to EA HH).
    • Landlord must verify that absent member was part of household and document date s/he was removed from the lease.
    • If loss of income is from employment, the family must demonstrate that employee did not:
      • Reduce earnings
      • Voluntarily terminate from job
      • Terminated for cause (as determined by DUA)
      • Must be rent-burdened, paying more than 50% of income toward rent and utilities.

¨       If a family vacates a unit at any point during an eviction case, without a court-order to do so, they will have been considered to have abandoned their unit, rendering them ineligible for shelter, despite the reason for the eviction, even if it was no-fault or excused-fault.

¨       A family who becomes homeless because their landlord chose not to renew their lease is not entitled to shelter.

¨       A family must have received the 48-hour notice of levy on execution in order to be eligible for shelter.

  • Families who leave or have left, within the past year, a doubled-up housing situation where, as determined by DCF assessment:

¨       The child(ren) (NOT the parent)in the household are sleeping a place not meant for human habitation, where the housing situation:

  • Lacks hot and cold water
  • Lack of heat in colder months
  • Lack of a toilet
  • Unsanitary conditions that result in the accumulation of garbage

¨       AND WHERE there is a health and safety risk to the child(ren) that is likely to result in significant harm should the child(ren) remain in that situation. A substantial health and safety risk is determined present when the child(ren) are exposed to, by the primary tenant:

  • Criminal activity
  • Mental health issues
  • Substance abuse

v      309.040 12 MONTH RULE

  • A household is not eligible for shelter or another shelter benefit for 12 months after the last day of shelter or shelter benefit ended.

LH/DS

Eligibility Changes

In response to the number of families in motels, surging costs, and continued high demand of the shelter system, the State is implementing changes to shelter eligibility which will limit the number of families that will be able to access the safety net of shelter. DHCD has issued a memo to the Division of Housing Stabilization which can be accessed here.

Effective immediately, families applying for shelter must demonstrate that they are a Massachusetts resident.  As you will note, the staff are not directed to share what types of documentation is required to prove residency until after they are informed they are not eligible.  There is also no directive regarding presumptive eligibility to provide shelter for a family that appears eligible but may need time to gather a document proving their past residency in MA or their intent to stay.  Community programs should be aware of these rules and prepared to field more calls from families seeking community beds or emergency placements.

Additional changes are subject to Legislative review per order of the budget language.  Most impacted by the eligibility restrictions will be families who are doubled up and asked to leave or who chose to leave a doubled up situation for reasons besides substantial heath and safety concerns which must be verified by the Department of Children and Families.

DHCD must provide the Legislature with proposed criteria to define “substantial health and safety risk” 15 days prior to implementing this new criterion.  All other changes are subject to a 60 day review period.

Technically, DHCD is not obligated to limit eligibility to the four categories as the budget language states “eligible families shall include”….as opposed to “eligible families shall be limited to”.  Personally, I feel it more responsible to collect data on the number of families that would be excluded if implemented and focus resources on learning if RAFT or other options would, in fact, assure the families’ safety…before implementing and determining the impact by putting children and families at risk.  We have 60 days to think about this important decision…and hopefully assess data about potential impacts.

LH

Why the focus on EA reform has been a step backward in our collective systems change efforts

In 2007, a Commission to End Homelessness was formed and charged with developing a 5 year plan to end homelessness. As the plan was finalized and rolled out, the economy crashed and the foreclosure crisis further depleted the housing stock. The family homelessness crisis expanded to become an unprecedented epidemic. While the recommendations did not account for the magnitude of the economic crash, there was considerable merit to the plan they put forth. Specifically, the Commission’s recommendations focused on a three pronged approach, listed here verbatim:

  • Prevention strategies to keep as many people housed as possible;
  • Housing placement, subsidy and production responses that result in stable, permanent housing options; and
  • Asset development supports that enhance the economic stability of individuals and families-perhaps the most meaningful protection against future homelessness.

Despite the considerable buy in of this prevention-housing-asset development approach, the direction of the Administration shifted to reforming the Emergency Assistance (EA) program. Proposals under this agenda have included: reductions to shelter eligibility, time limits, a reliance on short term subsidies, and cash assistance as an alternative to shelter.  The EA reform agenda counteracts the vision set forth in the Commission’s recommendations and dismisses core components needed to successfully end homelessness and create positive systems change.

Disregards Solutions to Homelessness

At the most fundamental level, the focus on EA reform neglects the root causes of our homelessness crisis: a shortage of affordable housing and wages that have not kept pace with rent.  As the Commission indicates, the solutions to homelessness are: preventing families from becoming homeless in the first place; having an adequate stock of affordable housing; and supporting families to maximize their internal, external and financial assets to obtain and maintain housing.  Focusing reform efforts on the shelter system does not result in progress towards these solutions.

A key theme to successful prevention is developing an early warning system by stopping evictions and having a coordinated and expansive network of resources.  The economic downturn has forced more families to the brink of becoming homelessness and provided an opportunity to immediately enact the recommendations to prevent individual cases of homelessness and prevent thousands of families from entering the system.  However, EA reform is a post-eviction response for families that are already homeless and therefore not effective at reducing the number of homeless families.  For example, the Commission had recommended expanding the Tenancy Preservation Program (TPP), which works within housing courts to stop evictions, to also include non-disabled heads of households.   However, instead of expanding the TPP program, the HomeBASE (Building Alternatives to Shelter Entry) program was developed as part of the EA reform initiative, and therefore families have to meet the EA eligibility standards, including a 48 hour notice to quit, eviction, or date of judgment, thus forcing families to become homeless rather than preventing their homelessness.

The Commission Report outlines four priorities for affordable housing production and access, including: developer incentives for production, increasing the number of vouchers, reducing the barriers to access housing and maximizing extremely low income units. Since the implementation of this plan, there has been little progress towards these goals.  Reforming the EA system does not address the housing problems, and as such, the housing problems have grown.  Our affordable housing stock is still grossly insufficient and production of extremely low income units remains a fiscal and bureaucratic obstacle course.  HomeBASE policies have also created additional barriers to accessing housing by forcing families to go through the eviction process and tainting their housing histories and/or implications on priority status. Recently, a state audit revealed an unacceptable lag time and favoritism to filling units at the Easton Housing Authority, and the media has highlighted similar concerns in housing authorities across the state.  If we are to truly implement a housing first approach to homelessness, we must address the issues in housing first. The reliance on the shelter system is a symptom, or result, of the state’s extremely low income housing shortage.  Focusing on the symptom can only result in a symptomatic solution.  Our goal is to end homelessness, which will require a permanent solution, a solution which must include the housing priorities outlined by the Commission.

Discounts the Roles of Key Stakeholders

The Commission Report acknowledges the need for shelter and service providers to play a key role in new system development, specifically acknowledging their service expertise.  However, since the recommendations were released, cuts have led to a reduction of this workforce and an elimination of prevention programs.  As new initiatives are rolled out under the umbrella of the Regional Nonprofits, shelter providers, community action programs and others have often been excluded in both the planning and administering of programs.  In a time of crisis, where more families are experiencing homelessness than ever before, the approach must be to maximize each stakeholder’s resources, experience, network and role.

When the recommendations were released, the focus was “systems change”. Individual instances of homelessness are often a result of system failures- failures of the housing system, the workforce systems, the education systems, the child protection systems, health care systems, and so forth.  Solving homelessness by focusing on the EA system negates the vital role that these other systems must play in stabilizing families and offering opportunities for families to achieve housing and economic stability. The EA reform approach focuses on limiting the number of families who can access shelter.  The Department of Children and Families has played a key role in this approach by creating another layer of scrutiny to access the safety net.  A systems change approach, on the other hand, would aim to maximize the role of DCF to develop innovative approaches to better support young parents aging out of or overlapping with their system, especially in supporting families as they transition into housing and/or while living isolated in motels.

Similarly, a systems change approach to ending homelessness would call on all state agencies to be accountable for solutions for subpopulations of families that intersect with their systems. The Commission recommended the following as priorities relative to non-housing systems: income maximization resources, school curriculums, and linkages to a continuum of services.  EA reform has not maximized the opportunities or leveraged the resources to address these priorities because it is a one silo approach. The EA silo is even evident within the Department of Housing and Community Development and its contracted programs, for example some Housing Authorities are unaware of the HomeBASE program and its policies. In addition there has been limited advancement in enrollment for Family Self Sufficiency Program and other asset development priorities.

Drives Demand in the Wrong Direction

A prevailing theme of the Commission Report was developing a No Wrong Door Policy.  Relative priorities included targeting prevention resources in communities determined to be homelessness hot spots; providing access to housing supports through all state agencies; and having supportive programs in communities.  Specifically, the Commission recommends programming de-linked to shelter.  However, the EA reform approach and the development of the HomeBASE program married housing supports to shelter eligibility.  EA reform talking points encourage families to double up, discourage the hope of a long term subsidy, and ask that homeless households rely on their own networks rather than the shelter and housing system. Yet, by having the shelter front door and the regional nonprofits be the primary administrator of flexible cash assistance (RAFT and HomeBASE), community based services have become a wrong door and supports are intrinsically tied to access points for shelter and permanent subsidies. Simply, EA reform implies the EA system is wrong, but puts most of the resources at the front door of the EA system.  The result was a 91% increase in shelter applicants during the implementation of EA reform principles.  Conversely, a systems change approach would seek to build up resources in communities and across systems so that families would not have to fall into the trap of the shelter safety net.

 Conclusion

The Patrick-Murray Administration set an aggressive timeline; the plan boldly declared it would, “succeed in ending homelessness in the Commonwealth by 2013”.  This week the Governor signed the FY13 budget.  While the number of families in the system has grown to an overwhelming and disheartening number and costs have skyrocketed, there are strengths we can draw upon to move forward in our collective efforts for positive systems change.  These strengths include:

  • A dedicated workforce who is invested in addressing this crisis
  • Different program models, practice approaches and hypotheses which have been tested
  • The Administration and Legislature have recently supported incremental investments in housing and prevention programs

Instead of “reforming” the EA system, the focus must be on the EA system-providers and families in it- “informing” the systems that are intended to support families avoid and overcome homelessness.  Homes for Families will focus on highlighting best practices from EA programs across the state. It is our hope and our challenge that the Administration will consider these practices and insights and refer back to the recommendations of the Commission and that together we can move forward with an agenda for positive systems change.  We will not solve homelessness by the end of 2013, but we can build upon successful programs, learn from policy failures, listen to each other, focus on root causes and holistic solutions and make every attempt to provide the right resources to the right people at the right time.

LH

Conference Committee Budget Analysis

On June 27th, the Conference Committee released their FY13 Budget which was voted favorably in both the House (3 nays, the rest yays) and Senate (unanimously).  Now, the Governor has 10 days to sign the budget and make any vetoes.  He does not have to take the full ten days.  The FY13 fiscal year began on July 1, and Massachusetts is currently operating with a short term budget.  Below is a chart outlining the key differences in the language, HFF’s recommendations and the final outcome from the Conference Committee is listed in red.

Housing and Homelessness Programs

FY2013 Conference Committee Budget

Compared to Homes for Families’ Recommendations

Line item Issue House Senate HFF Recommendation/Outcome
7004-0101Emergency Assistance Funding $88.9 million (+$16.6 million for motel funding, see 7004-0103 below = $105.5 ) $96.7 million Adopt House versionSenate amount but with the two line items: $80 million (+$16.6 million for motel funding)
  Families who go over income (115% FPL) EA benefits terminated 3 months after going over income EA benefits terminated 6 months after going over income Adopt Senate version Maintained 6 month language (Senate version)
  Eligibility “Includes” certain categories of families Restricts access to certain categories of families and protects eligibility for certain populations Adopt Senate versionSenate Language Adopted
  Time limit Places a 9 month time limit for families in shelter Families in shelter for more than 32 weeks are required to develop a shelter exit plan Adopt Senate versionSenate Language Adopted
  Access to HomeBASE No provision Disallows access to HomeBASE for families who have been in shelter for longer than 32 weeks Adopt House versionSenate Language Adopted;

Families remaining in shelter for longer than 32 weeks will not have access to HomeBASE Assistance

  Savings requirement Requires families to escrow a portion of income Requires families save 30% of their income Adopt House versionAdopted Senate language with exemptions based on FY12 regulations
  Advanced notice to legislature Requires 60 days advanced notice of changes to EA regulations Requires 30 days advanced notice of changes to EA regulations Adopt House versionAdopted House requiring 60 days notice for a reduction of benefits
  Scattered-site units No recommendation Requires DHCD to attempt to convert scattered site units into congregate shelters Adopt House versionAdopted Senate version
  Housing search No provision Requires DHCD to provide housing search for all families (including those in motels) within 16 weeks Adopt Senate versionAdopted Senate version
  Shelter contracts Requires DHCD to enter into 12 month contracts with providers No provision Adopt House versionLanguage was added, similar to the House language, mandating 7 month contracts
  Technical Assistance No provision Designates funding shall be allocated to HFF for tech. asst. Adopt Senate versionSenate language adopted
7004-0103Hotel/Motel Funding $16.6 million Does not exist Adopt House versionNew Line Item adopted, as proposed by the House
7004-0108HomeBASE Funding $83.4 million $90.8 million Adopt Senate version$83.4M- House Amount

 

  Per household funding Up to $4,000 per household Up to $6,000 per household Adopt Senate versionHouse Version Adopted
HomeBASE (cont.) Rent cap 80% of HUD defined Fair Market Rent No cap Adopt Senate versionAdapted Senate version

 

  End of rental assistance, EA access Family who is terminated is ineligible for shelter  and/or HomeBASE for 1 year Family who is terminated is ineligible for shelter and/or HomeBASE for 2 years Adopt House versionAdopted House version
  Over income families Families entered prior to July 1, 2012 have 6 months to exit after income exceeds 50% AMI; families entering after July 1 have 6 months to exit after income exceeds 115% FPL All families whose incomes exceed 50%AMI have 6 months to exit program Adopt Senate versionAdopted House Version
  Access for EA families No reference Disallows access to EA families who have been in shelter longer than 32 weeks Adopt House versionAdopted Senate Version
7004-3045Tenancy Preservation Program Funding $250,000 $500,000 Adopt Senate version$350,000
7004-9005 Public Housing Operating Subsidies Funding $64.5 million $62.5 million Adopt House versionHouse Funding: $64.5M
7004-9024Mass. Rental Voucher Program Funding $46 million $42 million Adopt House versionSenate Funding: $42M
  Targeting of new vouchers 923 vouchers for families residing in shelters or motels Sets aside $800,000 for the development of supportive housing for families and individuals Adopt Senate supportive housing, any additional vouchers, House versionNo targeting language
  Income eligibility 200% FPL 50% AMI Adopt Senate versionHouse Language: Maintaining the  200% of FPL as the cap
  Administrative fee $30 per voucher per month $32.50 per voucher per month Adopt Senate versionSenate version adopted
7004-9316Residential Assistance for Families in Transition Targeted population to be served Not less than 65% of funding goes toward families at or below 15% AMI Not less than 90% of funding goes toward families at or below 30% AMI, prioritizing families who would otherwise be eligible for shelter Adopt Senate versionSenate Language Adopted
  Per household funding Up to $4,000 Up to $6,000 ($4,000 from RAFT, additional 2 from HomeBASE if deemed appropriate) Adopt Senate versionHouse Language Adopted

Click here for Mass Law Reform’s Analysis of how the budget will impact homeless and low income families. 

LH