New Rule Shows Need to Rename DC’s Rapid Re-Housing Program

The District’s Department of Human Services has issued another emergency rule* for its rapid re-housing program — formally named the Family Re-Housing and Stabilization Program. The notice says that the agency intends to make this one permanent.

It’s got me wondering what DHS has in mind for its rapid re-housing program — and what we should have in mind. Here’s why.

DHS has, in the past, looked to rapid re-housing as its main tool for getting homeless families out of the DC General shelter quickly so as to free up space for more. That has never worked out as planned, but it’s still apparently reflected in the agency’s budget for the upcoming fiscal year.

The budget assumes only 150 families at DC General and allocates no funds whatever for hotel rooms if this assumption proves egregiously over-optimistic.

So you’d think that DHS would give its all to make rapid re-housing an attractive option for homeless families — and to get all takers rapidly re-housed. You’d also think its recent experience with the Mayor’s 500 Families in 100 Days campaign would have made an imprint.

I’m thinking here about how the campaign managed to identify something pretty close to the targeted 500 acceptable units landlords would rent to families with only short-term housing subsidies.

Lots of outreach by nonprofits that had relationships with potentially willing landlords. Efforts to acquaint them with rapid re-housing — something hopeful parents couldn’t always do on their own. Reassurances that reportedly included promises of financial help if tenants defaulted.

Yet the FRSP rule instead requires homeless families to find suitable units, sign leases for them and actually move in within 30 days.

As a fallback, they can attempt to prove they’ve done their best to find a unit that a landlord will rent to them at a rate consistent with the applicable affordability standard — and one that can pass inspection.

Only then can the service provider they’ve been assigned to offer them a unit that’s already been identified as suitable and available, assuming such exists. The rule makes no provision for maintaining an inventory of units.

The burden on homeless families is consistent with what the emergency rule says FRSP will do — “provide District residents with financial assistance for purposes of helping them become rapidly re-housed” (emphasis added).

Staying re-housed is a whole other matter. DC Fiscal Policy Institute analyst Kate Coventry notes that families must initially pay 40% of their rental costs, rather than the 30% that’s used for public housing and indefinite-term housing vouchers — and more generally, as the maximum for housing affordability.

Families will then become responsible for increasing shares of their rent every four months, when their provider decides whether they’re still eligible for rapid re-housing. Or at the very least, their ability to pick up a bigger share will be a factor.

This is consistent with initial eligibility, as the rule defines it. Only families providing information leading to “a reasonable expectation” that they “will have the financial capacity to pay the full amount at the end of the FRSP assistance period” can qualify.

So in one respect, shifting the rent burden to them at four-month intervals might seem reasonable, especially because they’ll get no subsidy at the end of a year — unless their need for further assistance is “caused by extraordinary circumstances.” What those might be the rule doesn’t say.

We can assume, however, that merely lacking enough money to pay the rent won’t suffice. So a reality check seems in order.

Families who’ll get top priority for FRSP are those in a publicly-funded shelter or transitional housing and those who’ve been designated Priority One because they have no safe place to spend the night.

A large majority of those at DC General are enrolled in the Temporary Assistance for Needy Families program. This means they are dirt poor and relying, at least officially, on benefits that wouldn’t begin to cover rental costs in the District.

By way of reference, the maximum monthly benefit for a family of three will probably be about $438 come October. A modest one-bedroom apartment costs, on average, roughly $1,240 a month, according to the U.S. Department of Housing and Urban Development’s fair market rent calculations.

So a family that’s relying on TANF would have to rapidly bootstrap its way up the income scale to avoid becoming homeless again when its FRSP subsidy expired. And I do mean up. A full-time minimum wage job would leave the parent in our three-person family with about $305 for expenses after s/he paid the rent on the FMR apartment.

In short, FRSP, as now designed, may rapidly re-house homeless families. But it shouldn’t lay claim to stabilization. And though the name still does, the new rule doesn’t.

DCFPI’s comments on the new rule observe that the one it replaces defined the purpose of the program as “assisting … [families] to obtain and remain in a new rental unit.”

Now “and remain” is gone. And the rule is utterly silent on services that might help some rapidly re-housed families become stably housed, though one infers they will receive case management of some sort.

Arguably, even a year (or less) in a reasonably decent private apartment is better than enduring conditions at DC General. But respite from shelter isn’t what rapid re-housing is supposed to be about.

It’s undoubtedly all that some families need to get through a bad patch, e.g., an injury that sidelined the breadwinner for awhile, an over-long break between contracts.

And it’s altogether possible that some other families will overcome barriers that have made them unable to afford market-rate rents for a long time. But I doubt we’ll find all that many of them at DC General — or entitled to shelter, if it’s freezing cold, because they’re designated Priority One.

And I suspect DHS shares these doubts. How else to explain the retreat from the goal of stabilization?

* Unlike ordinary rules, emergency rules become effective immediately, rather than after the public has had an opportunity to comment. The District’s Administrative Procedures Act says they are for occasions when “the adoption of a rule is necessary for the immediate preservation of the public peace, health, safety, welfare, or morals.”

 

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2 Responses to New Rule Shows Need to Rename DC’s Rapid Re-Housing Program

  1. […] New Rapid Rehousing regulations fall short of key goals (Poverty & Policy) […]

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