Research & Innovations

Housing Mobility

PHAs are developing innovative strategies to enable more voucher residents to live in high opportunity neighborhoods with access to resources critical to their long-term success. There is considerable research suggesting that HCV program participants, especially those with young children, achieve better outcomes when they are able to use their voucher in a safe neighborhood with access to quality schools. CLPHA, along with the Poverty and Race and Research Action Council (PRRAC) sponsors the biennial National Housing Mobility Conference, which features presenters from the realms of research, policy, and practice to bring attendees up to date on developments in the field and spark discussions that will push the work forward.

Housing Mobility News

4.25.23

CLPHA, Reno & Cavanaugh Submit Comments on AFFH

CLPHA, Reno & Cavanaugh, and the MTW Collaborative have submitted comments on the proposed Affirmatively Furthering Fair Housing (AFFH) Final Rule. CLPHA and Reno underwent a lengthy feedback-gathering process that included several meetings with members to develop these draft comments. 

The Proposed Rule fails to provide PHAs with the necessary tools to produce the contemplated AFFH deliverables. At the same time, the Proposed Rule creates an enforcement framework that penalizes PHAs for failing to produce these deliverables. The Proposed Rule also continues to be administratively burdensome and arguably constitutes an unfunded mandate.

PHAs will be required to create and update Equity Plans as a component of AFFH. We are also concerned that the Proposed Rule contemplates the commencement of the Equity Plan process before a final rule has been issued. In practice, this would mean that a PHA whose plan or consolidated plan is due in 2024 would be required to submit its Equity Plan this year, which is an impossible deliverable.

The letter notes that PHAs are committed to affirmatively furthering fair housing and therefore appreciate HUD’s efforts to streamline the AFFH requirements to enable PHAs to meet their AFFH obligations while minimizing administrative burdens on PHAs. We applaud HUD’s efforts to promote equity in housing. Fair housing is a fundamental and critical component of the mission of PHAs.

Key points in our letter include:

HUD Has Not Made Adequate Current and Historic Demographic Data Available to PHAs to Conduct the Equity Analyses Required under the Proposed Rule.
The Accountability and Transparency Mechanisms Contemplated in the Proposed Rule Expose PHAs to Greater Liability and Unnecessarily Frustrate the AFFH Decision-Making Authority and Process of PHAs.
The Proposed Rule Fails to Consider How Moving to Work Agencies Can Play a Critical Role in Promoting AFFH by Increasing Housing Choice and Expanding Access to Affordable Housing by Non-MTW Agencies.
The Proposed Rule Does Not Adequately Address the Administrative and Cost Burden Problems of the Previous AFFH Rule.
Specific Comments to Equity Plan Requirements

We appreciate all our members that provided feedback to help craft our letter. The comment window on AFFH closed on Monday, April 24.

CLPHA Comment Letter on AFFH

4.25.23

CLPHA Comments on NSPIRE Scoring Methodology; NSPIRE Scoring Calculator Now Available

Recently, CLPHA held a series of listening sessions to hear members’ concerns with HUD’s proposed NSPIRE Scoring Methodology. CLPHA has prepared comments on the proposed rule for members to review. Members are encouraged to use CLPHA’s letter to guide their own comments. Comments are due to regulations.gov on Thursday, April 27.

CLPHA is very concerned that HUD is seeking comments on the NSPIRE scoring methodology prematurely. HUD has not concluded its NSPIRE demonstration or provided scores to PHAs that participated in demonstration inspections. In the NSPIRE Proposed Scoring Notice, HUD admittedly states that certain standards “may need more calibration through field testing”. Yet, we are being asked to provide input on the Scoring Methodology in the absence of a fully transparent environment on an accelerated 30-day timeline. Likewise, the demonstration never provided an opportunity for participating PHAs to provide feedback on their experience. Without access to demo scores, the industry is unable to properly evaluate the Scoring Methodology.

Key recommendations made in CLPHA’s comment letter:

Delay the implementation of NSPIRE beyond 2023 and until the challenges detailed in CLPHA’s comment letter are fully addressed.
Allow PHAs a minimum of one year after NSPIRE’s final rulemaking is completed prior to beginning NSPIRE inspections of record.
Provide advisory scores during the implementation period
Provide NSPIRE demo participants with scores
Conduct iterative review of Scoring Methodology during implementation
Provide more time to use the Score Calculation Tool
Provide clarity on the formula

HUD REAC has also published a NSPIRE Scoring Calculator following CLPHA’s advocacy. The Scoring Calculator can be used to estimate a potential NSPIRE score based on the types and locations of deficiencies identified during an NSPIRE inspection. This score only provides an estimate as many factors will impact the actual score generated by a property inspection. HUD also released a video tutorial showing how to use the Scoring Calculator. CLPHA recommends that members use the tool to evaluate potential NSPIRE scores and provide feedback to Malcolm Guy at [email protected].

CLPHA Draft Comment Letter

NSPIRE Scoring Calculator

4.21.23

Secretary Fudge Defends HUD FY24 Budget at Congressional Appropriations Hearings

On April 18, 2023, the House Committee on Appropriations Subcommittee on Transportation, Housing and Urban Development, and Related Agencies (THUD) convened their first budget hearing for the fiscal year (FY) 2024 request for the Department of Housing and Urban Development (HUD). Secretary Marcia Fudge, the only witness, was tasked with defending HUD’s budget before Subcommittee Chairman Tom Cole (R-OK), Ranking Member Michael Quigley (D-IL), and other members of the subcommittee panel. While Republicans affirmed that HUD would not see a budget increase in FY 2024, Secretary Fudge staunchly advocated for the funding that housing authorities need to serve the most vulnerable families in their communities and outlined the dire consequences that would result from failing to increase HUD funding in the next appropriations bill.

The Senate Committee on Appropriations THUD subcommittee held their hearing related to the FY 2024 HUD budget request two days later on April 20, where Secretary Fudge again defended HUD’s budget request before Subcommittee Chairman Brian Schatz (D-HI), Ranking Member Cindy Hyde-Smith (R-MI) and other panel members.

Some Highlights from the House and Senate Hearings

HOUSE HEARING OVERVIEW:

During the House hearing, Chairman Tom Cole began by acknowledging the discussions surrounding proposed cuts to the FY 2024 budget. Chairman Cole mentioned that HUD would unlikely see an increase in the FY 2024 Budget. However, a continuing resolution was a concern for both parties.

In her testimony, Secretary Marcia Fudge stated that the FY 2024 budget reflected the Administration’s commitment to providing safe, affordable, and equitable housing to our underserved communities. The Secretary emphasized the Administration’s first-of-its kind proposal for mandatory funding of $104 billion over 10 years to provide additional housing assistance. The Secretary also expressed her concern regarding proposed budget cuts in FY 2024 which would have a serious impact on HUD and the communities they serve.

Proposed Cuts to the HUD Budget:

Chairman Cole, Ranking Member Quigley, Congresswoman Bonnie Coleman (D-NJ), and Congresswoman Norma Torres (D-CA) of the House subcommittee asked Secretary Fudge what the impacts would be on HUD and federally assisted housing if the federal government operated with the following circumstances:

Continuing resolution (CR): Secretary Fudge shared that over 125,000 people currently served by HUD would lose their homes. HUD would be $500 million short in renewing Project-Based Rental Assistance (PBRA) contracts and would serve 32,000 fewer people who are experiencing homelessness. The department would also have difficulty maintaining their IT systems, putting residents’ information at risk.

Secretary Fudge mentioned that there would also be a major setback for housing authorities because HUD wouldn’t know how much rent they could pay. Fudge stated that as a former mayor and member of Congress, she understood the difficulty of passing a budget but said that “I would just ask you to consider the fact that you do not want to balance a budget on the backs of poor people.” She added, “We serve about 4 million people a month...I would hate to put them, public housing authorities, our private partners, [and] our contractors in a position where they have no idea where we go next.”

20 percent cut to the HUD Budget or Operating at FY 2022 funding levels: Secretary Fudge stated that a 20 percent cut to the HUD budget would be significantly worse than a CR. Housing authorities would be unable to conduct inspections, and public housing would become significantly worse due to the capital improvements that need to be done. “HUD itself does not provide housing; our partners do.” Public housing would not be able to work on capital improvements. The department would have difficulty continuing to recover from the effects of COVID, which destroyed payment plans.

If HUD were to operate at FY 2022 funding levels, the Secretary shared that 640,000 people currently served by HUD would lose their homes. HUD would be $4 billion short for renewing Public Based Rental Assistance contracts and would serve 95,000 fewer people who are experiencing homelessness. Secretary Fudge stated that “We are one of the very few agencies that directly impact people’s lives.”

Homelessness, Justice-Involved Individuals, and Health:

Members from both parties discussed their concerns for the homeless population, mental health, and justice involved individuals.

Congressman Juan Ciscomani (R-AZ) asked how the federal government can help HUD, landlords, and housing authorities to improve landlord engagement to ensure individuals such as people experiencing homeless can obtain housing in the private market. The Secretary acknowledged that HUD programs need landlords, and they are currently working on initiatives to incentivize and engage landlords.

Congressman Ben Cline (R-VA) discussed policies related to homelessness and mental health. The Congressman shared that his district expressed concerns from homeless service providers regarding programs and policies that do not treat underlying causes of homelessness such as mental illness. He asked, “Why is HUD using old data to inform policies? Why do we conduct PIT (point-in-time) counts during the coldest month of the year AND why is it only once a year?” Secretary Fudge shared the same concerns regarding data collection and aggregation.

Congressman John Rutherford (R-FL) praised the continuum of care program and how the wraparound services are significant to the community, especially justice-involved individuals. He acknowledged that housing is a big challenge for those who are justice-involved. He noted his involvement in the second chance re-entry task force, a bipartisan task force focused on creating policies to help justice-involved individuals seek housing, employment, and health care.

Lead hazards in public housing were mentioned by both parties. Congressman Rutherford asked how HUD was prioritizing lead removal. Congressman Adriano Espaillat (D-NY) expressed concerns regarding the Rental Assistance Demonstration (RAD) program and if it can be used to remove lead in housing. The Secretary shared that lead removal is a huge priority with HUD.

Congressman Peter Aguilar (D-CA) asked how HUD is working with departments such as Health and Human Services (HHS) and Medicaid services to access health care services for people experiencing homelessness. During this questioning, the Secretary shared that “housing really is a social determinant of health.”

While the HOME Investments Partnership Program (HOME) and Community Development Block Grant Program (CDBG) are rumored to be on the chopping block for cuts this year, only HOME was discussed by Republicans during the hearing. Concerns surrounding the HOME spend out rate were expressed in skepticism for more funding, when additional and substantial funds were given in the American Rescue Plan Act, and questioning why HOME funds are difficult to use.

SENATE HEARING OVERVIEW

The center of discussion for the Senate THUD appropriations subcommittee hearing also focused on housing and health, homelessness, and landlord engagement in the Housing Choice Voucher Program (HCVP). Both parties expressed their concern for the homeless population, especially families and children and rural areas. Secretary Fudge also conveyed the importance of ensuring that the FY 2024 funding request for HOME is important to increase affordable housing. According to the Secretary, the proposed budget for the HOME program will bring about 15,000 new homes if the FY 2024 request is enacted.

Health And Housing

Subcommittee Chairman Schatz discussed the barriers of using Medicaid waivers to support case management and housing services, especially for people experiencing homelessness. The Senator shared that complications and delays with billing impedes providers from helping the homeless population. Chairman Schatz asked the Secretary how HUD is helping with this challenge. The Secretary shared that HUD and HHS launched a joint technical assistance center. HUD is speaking with different groups to see how they work around certain regulations and provide technical assistance to providers who use the waivers.

The Secretary also announced that $25 million will be allocated to housing authorities for supportive services and more resources for mobility services next month. However, funding like this would be significantly lessened if Congress maintained FY 2022 levels.

Homelessness

Subcommittee Ranking Member Hyde-Smith voiced her concern for homelessness in rural areas and asked for the Secretary’s commitment to improving this problem.

Vice Chair Susan Collins (R-ME) of the Senate Committee on Appropriations asked, “What are we doing for the homeless population who are elderly?” The Secretary shared that the challenge is that we do not have enough senior housing or housing where people can age in place.

Landlord Engagement

Senator Collins asked how we can encourage landlords to house individuals experiencing homelessness, especially those who are chronically homeless. The Secretary acknowledged that engaging landlords to house individuals experiencing homelessness is difficult. However, the Secretary shared that offering master leases to certain properties, creating toolkits to serve as resources, and finding incentives can improve landlord engagement.

Choice Neighborhoods Initiative

Senator Christopher Van Hollen (D-MD) and Senator Christopher Coons (D-DE) voiced their support for the Choice Neighborhoods Initiative (CNI). The Secretary offered that CNI truly transforms neighborhoods and helps these communities with moving away from segregation based on poverty. However, the Secretary did note that there needs to be more resources for CNI.

Special Purpose Vouchers

Many CLPHA member PHAs participate in special purpose voucher programs, such as the Family Unification Program (FUP), the Department of Housing and Urban Development and Veterans Affairs Supportive Housing Program (HUD-VASH), and the Non-Elderly Disabled (NED) program. These programs serve especially vulnerable low-income households who are in need of supportive services to ensure long-term housing stability. CLPHA members have created a variety of innovations to more effectively serve program participants.

HUD-VASH Exit Study - Final Report

Member Profile

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