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Tuesday, September 16, 2014

Is your community prepared to receive federal funds to fight homelessness?

One of the few positive trends in affordable housing over the last five years is the reduction in chronic homelessness nationwide. The U.S. Department of Housing and Urban Development's (HUD) definition of chronic homelessness is individuals that have been homeless for more than one year or that have had four or more episodes of homelessness in the past three years. In addition, HUD recently reported a decrease in homelessness among veterans since 2010.

How did this happen? Starting about 10 years ago, a consensus began building among the White House, Congress, and state and local governments, that ending chronic homelessness should be prioritized. As more programs began to demonstrate success in reversing the trend of growing chronic homelessness, more decision-makers got on-board (i.e. the Housing First model). Now there is general agreement among a majority of lawmakers, administrators and activists that homelessness is not good for the economy, it wastes public resources, and that there are proven models to reduce it.

This does not mean that general homelessness has been reduced in every community, and many communities are seeing more of it now than ever before. While federal funding for fighting homelessness has been steady over the last five years, it has not increased adequately to address the impacts of the recession and growing inequity on those living near the edge of homelessness. However, recent progress does show what can happen when all levels of government, local nonprofits and citizens get on the same page to support strategies that work.

So you may ask yourself whether your community is positioned to take advantage of the recent federal interest in ending homelessness. To do so, one must understand where the federal priorities are currently and anticipate where they will be over the next few years.

The principal federal funding program to address homelessness is HUD's Continuum of Care Program. In 2009, the HEARTH Act was passed to consolidate the former McKinney-Vento programs and prioritize funding to communities that coordinate resources for maximum efficiency and efficacy. The organizations that coordinate services and apply for funds are called Continuums of Care (CoCs). Their memberships consist of all entities that collaborate within a local geography (usually a County) to combat homelessness: government agencies, nonprofits, civic groups, etc.

The CoC Interim Rule (24 CFR Part 578; Vol. 77, No. 147) laid out HEARTH Act requirements for CoCs. These requirements include: establishment of a board or governing body, Lead Agency, and a Collaborative Applicant that submits the application to HUD on behalf of the COC; conducting a homelesess census every two years; and implementation of a Homeless Management Information System (HMIS). The HMIS provides a method to consistently measure the characteristics of the homeless population, available services, and progress toward goals.

The following are areas where CoCs should prepare to meet potential future HUD regulations and guidelines.

1.  Become familiar with Proposed HMIS Rule (24 CFR Parts 91, 576, 580 and 583; Vol. 76; No. 237).  It includes specific guidance on operating HMIS, including administration and development of data quality, security and privacy plans. Develop policies and procedures that adhere to the Proposed HMIS Rule, and the 2014 HMIS Data and Technical Standards.

2.  Establish a Governance Charter for the CoC that lays out the roles and responsibilities of the governing body (or board), committees, the Lead Agency, the Collaborative Applicant and the HMIS Lead Agency.

3.  Plan for a Coordinated Assessment System. This is a method of organizing the intake and assessment of homeless individuals across the CoC to maximize efficiency of services. The idea is to eliminate duplicative intake processes and better serve individuals through coordination.

Communities that undertake these steps will enhance their competitiveness to receive federal funds in the coming years. Feel free to let me know if you have specific questions about undertaking these steps.

Thursday, September 4, 2014

Did you forget about the 2013 Final HOME Rule? A focus on monitoring

If you use or advocate for the use of HOME funds, you'd probably like to forget about the 2010-2011 period- the recession, the debt limit wars, the media focus on nonperforming projects, the slashed budgets. That all led to the 2013 Final HOME Rule.

I had conveniently put it out of my memory when I was preparing a scope of work to conduct some rental project monitoring. But then it was brought to my attention- Participating Jurisdictions (PJs) actually don't have to do a complete site inspection every year for projects with more than 25 units anymore. That was the old rule that was still stuck in my head.

The monitoring component of the 2013 Final HOME Rule for rental projects is actually an improvement on the old regulations, from the PJ perspective. It allows for a more flexible and streamlined process that gives the PJ more discretion on where they choose to spend their time. This is a welcome change given that the timeline requirements for completing projects was significantly ratcheted up while administrative funding was cut.

The monitoring requirements are found in Section 92.504 of the 2013 Final HOME Rule. Here is the skinny on what's new:

  • At construction completion, the PJ must inspect the property for completion and compliance with the property standards found in Section 92.251 [92.504(d)(i)].
  • Ongoing site inspections do not have to be conducted every year, but can be done once every three years as long as there is no reason to follow up on non-compliance issues [92.504(d)(ii)].
  • The property owner must annually certify to the PJ that the property is suitable for occupancy and that it is in compliance with code and the HOME property standards found in Section 92.251 [92.504(d)(ii)(C)].
  • The PJ must annually examine the financial condition of HOME-assisted projects with 10 or more units for financial viability [92.504(d)(iii)(2)].
A couple recommendations:
  • Take a look at your old property inspection forms and make necessary revisions to bring them in line with the new HOME Rule Section 92.251 property standards. HUD has made a number of revisions to these standards. 
  • Start your financial condition examination with a review of the property's most recent audited operating statement.

Tuesday, September 2, 2014

Viewing housing beyond the four walls, and what it has to do with Ferguson and HUD

In America, we generally suppress discussions about inequity. We don't want to believe it exists, but it's always bubbling beneath the surface. Then a volcano erupts, seemingly out of nowhere to those who aren't paying attention, and we wonder why. In the wake of the latest eruption in Ferguson, racism and upward mobility have been more closely analyzed as factors in recent media coverage. Those factors should lead to a more holistic analysis of housing; that is, housing as a place, not just a product.

Five years ago, the Great Recession and the bailouts precipitated the 99% vs. 1% demonstrations. Due to these demonstrations and the widely felt economic pain, people started paying more attention to the huge income disparities in this country, not only in terms of current wealth, but more importantly in terms of unequal wealth growth over the last 30 years. Here's a powerful illustration.

To date, our national political leaders have proposed narrow, high-impact policies, such as tax credits for low-income households and an increase in the minimum wage. These are targeted measures that put money in people's pockets and make a significant economic impact. These policies address income inequality in the short-term, but they do not adequately address how we got here- the lack of income mobility. For example, do wage-based tax breaks or wage minimums help you climb to the next rung of economic success?

With Ferguson, questions about race and disparity between neighborhoods have invited a more expansive and constructive discussion. What does where you live have to do with income mobility? As it turns out, it has a lot to do with it. Neighborhoods provide residents with varying levels of access- to quality schools, jobs, recreation, clean air, healthy foods, and to the rest of the city with affordable transportation. Maybe most importantly, neighborhoods have social networks. If those networks include connections to people actively involved in politics, education or business, the residents will generally be much better off. The quality of these neighborhood social networks have an even greater impact on access for residents of low-income neighborhoods with poor public transportation.

We need to look at housing as an access point to opportunity, not just as a commodity. For example, we should be looking at more than housing affordability to gauge the affordability of living in a particular location. A study by the New York Citizens Budget Commission has been making the rounds lately, showing that New York City is actually one of the more affordable cities to live in even though it has one of the most expensive housing markets (summary from The Huffington Post). That's because transportation costs were figured into the equation, and NYC has the best public transportation system in the nation.

Within this framework of neighborhood access and assets, our nation's housing policies can make a big difference, and HUD has actually been leading the way in changing the approach from a federal level. The Obama Administration has been pushing an approach that focuses on place rather than solely focusing on programs. The Administration is really big on what is known as "place-based community and economic development", and it is advocated by think tanks such as Policy Link.

The idea is that sustainable, positive community change is only possible when we invest in local institutions in a strategic and coordinated way- schools, community colleges, libraries, community development corporations, etc. These institutions are usually run by community members, and therefore they know what the community needs and can draw on their social networks to meet those needs. This opens mentoring opportunities and career paths to residents. The White House Office of Urban Affairs found that "sustained exposure to disadvantaged neighborhoods is associated with a 60-80% decrease in the odds of high school graduation (see White House link below)." In addition, place-based investments have a better chance for sustained success than programs instituted from outside entities. This is because investments are placed in people and institutions that stay in the community and grow in capacity.

HUD and other federal agencies have made some important first steps to implement place-based strategies. Agencies such as DOT and HUD are actually coordinating research and planning to offer their resources to communities, which really hasn't happened in the past. Still, we have a long way to go, as Ferguson demonstrates. Since place-based strategies apply the philosophy of bringing more control and decision-making to the local level, I would hope that there is enough common ground to be found between the Left and the Right to advance it after Obama leaves office, but that will be challenging given today's polarized political environment. Success will only come with a sustained commitment at the federal, state, regional and local levels.

Here are some links where you can find out more about HUD and other federal efforts to implement place-based development.

White House's Neighborhood Revitalization Initiative
Summary of HUD's Choice Neighborhoods Initiative
HUD Promise Zones
Summary of the HUD/DOT Location Affordability Portal
HUD Location Affordability Portal