DC Gets a Barely Passing Grade for Homeless Family Services

December 10, 2014

Last spring, a coalition of advocates and service providers developed a “roadmap” for preventing another wintertime homeless family crisis in the District of Columbia. Now, as a new winter season opens, it’s issued a report card, indicating how much progress the District has made toward the 10 goals the roadmap set.

Not the sort of report card you’d like to take home to your parents. Virtually all Cs, meaning the District has taken steps toward the goals, but too recently for the coalition to decide whether they’ll result in significant progress.

Two Ds, meaning no significant progress — or, one infers, much by way of promising steps. And a single B, for homelessness prevention. That seems pretty generous to me, since the progress described has thus far not resulted in an “up and running program.”

Like the original roadmap, the report card reflects a lot of effort to gather, assess and communicate information about the District’s homeless family services. Highly recommended reading for all concerned. I’ll confine myself here to the big picture, as I see it.

Not Enough Shelter Units (Again)

As you may recall, the Department of Human Services was overwhelmed last winter by homeless families it couldn’t legally turn away because they’d sought shelter during freezing-cold weather.

One, though not the only problem was that DC General, the main shelter for homeless families, was nearly full when the winter season began. The roadmap recommended both a plan and additional staff to move at least 100 families a month from shelter into housing so as to open up space for more.

DHS has managed to increase the rate to 63 families a month — not enough to have significantly more vacant units at DC General when this year’s winter season began. To its credit, it has contracted for hotel rooms. But there was no money in the budget for them.

The agency plans to use funds from the Temporary Assistance for Needy Families program — an estimated $8.5 million, I’m told. Hard to see how this won’t mean cutbacks in programs and/or services those TANF funds would otherwise support.

At the same time, as I’ve written before, the Gray administration has proposed a plan (of sorts) to replace DC General with smaller shelters. The total number of units would remain the same.

So there’d probably still be fewer units than homeless families entitled to shelter during the winter season — and surely too few for the District to once again keep the shelter doors open year round for families who’d otherwise have no safe place to stay.

More Affordable Housing, But Mostly Temporary

On the upside, the District has invested funds to support the development and preservation of affordable housing, including apartments big enough for larger families. And the DC Council has approved more funds for vouchers that enable homeless families to rent at market rates.

But the District’s strategy relies heavily on rapid re-housing, i.e., short-term housing subsidies, renewable for up to a year, provided that families measure up to expectations.

DHS has still not issued final rules for the program. And the theoretically temporary rules it issued in late June raise serious concerns — among them, the share of rent families have to pay, both initially and during renewal periods.

The rules are also highly ambiguous about whether families can get an extension of their subsidy if they can’t afford to pay full rent at the end of the year — a likely possibility for many, I’ve suggested.

DHS could, at the very least, enable nonprofit partners to provide some services and/or rental assistance to families that seem likely to become homeless again. But it hasn’t even explored the possibilities, the report card says.

One Small Step for Young Families

More than 40% of the families sheltered last winter were headed by parents who were, at most, 24 years old. Needless to say (I hope), they had very little, if any work experience. Many, the report card says, had neither a high school diploma or the equivalent — a high predictor of unemployment, even for older District residents.

Like as not, the young parents had never rented an apartment. Some probably had just aged out of foster care, since that’s a high risk for homelessness.

They often don’t have ongoing family support or other concerned adults to help with the challenges of housing, credit and the like. The same, of course, can be true for young mothers who were kicked out — or harassed out — of their homes when their parent(s) found out they were pregnant.

These are not the sort of families that rapid re-housing was designed for. Nor the sort of families that the needs assessment tool DHS relies on was designed for. The roadmap, therefore, called for reviews of the tool, the case management system and rapid re-housing itself to ensure they’re suitable for young families.

DHS has launched a small pilot program, which offers the fortunate participants more intensive services and potentially rental assistance for more than a year.

It’s not clear whether the agency can expand the program, the report card says. Nor is it clear whether DHS has reviewed — let alone modified — the tool or case management services.

Much Else Unclear

Families first encounter the District’s homeless system at the Virginia Williams intake center. Caseworkers there still have no written protocol to tell them how to decide whether to grant a family shelter. Nor, therefore, do we know how decisions are made — only that some indicate ignorance (or casual disregard) of the law.

That’s far from all we don’t know. For example, the District doesn’t release information on services families receive while they’re at DC General. More generally, it either doesn’t have or won’t release data that would enable us to determine how key elements of its homeless system are working — apparently more the former than the latter.

Part of the problem, the report card says, is that DHS contracts out much of homeless services to the Community Partnership for the Prevention of Homelessness. And the Partnership doesn’t deign — and isn’t required — to publicly report how it spends the funds it gets or what they achieve.

Thus, as the report card says, “it is impossible to determine if the District has allocated sufficient funding to meet the need and if programs are performing as well as they should be.”

Impossible for the roadmap coalition, which so clearly wants to help create a humane, effective system that prevents homelessness, when possible, affords shelter when that isn’t and then helps families move quickly to a safe, stable home.

Impossible for our policymakers as well. But they can make the egregiously opaque system more transparent. This ought to be a first order of business for the new administration and the new chair of the Council’s Human Services Committee.


DC TANF Families Face Benefits Cut-Offs With Dim Prospects for Steady Work

December 8, 2014

In early 2012, the D.C. Department of Human Services launched a redesigned Temporary Assistance for Needy Families program. As with TANF programs nationwide, it aimed to move very poor parents with children toward self-sufficiency, i.e., work that pays enough to support the family — or at the very least, too much to make them still eligible for TANF.

Now we have an in-depth, though partial view of the results. A recently-completed review of the TANF employment component found, among other things, that fewer than half the target group of parents who, with help, had found jobs were still employed.

But even this finding overstates the self-sufficiency prospects for the more than 6,000 families who may soon have no cash income whatever because the DC Council set a retroactive 60-month lifetime limit on benefits in late 2010 and a phase-out schedule ending in total cut-offs next October.

About the Review

The Office of the District of Columbia Auditor analyzed data and other information that DHS provided, with a view toward providing the basis for some conclusions about the outcome of what it refers to as the TANF Employment Program.

The program consists of two related types of services — work readiness and job placement. Both are provided by contractors. Work readiness contractors, as the term suggests, are supposed to help parents strengthen their qualifications for paying work.

But they are responsible for helping the parents find jobs as well. This is the only thing the job placement contracts are supposed to do because the parents assigned to them have been deemed ready to work.

The auditors focused only on parents who had received TANF benefits for more than 60 months because these were the parents whom DC Council Human Services Committee Chairman Jim Graham asked about.

They looked at data collected over about 32 months — from the time the new employment program began, in February 2012, to October 24, 2014. Graham wanted results by early November.

So the auditors were up against a tight timeframe. As a result, they’re careful to say, they didn’t verify what they got from DHS, as they ordinarily would.

Jobs of Any Sort for Fewer Than Half

Though the two types of employment services differ in scope, they’re both intended to get TANF  parents into — or back into — the workforce and earning enough to no longer qualify for TANF. For a family of three, that would have been anything over $588 a month in 2012-13, assuming no other income.

The auditors report that about 49% of parents referred to an employment services contractor got a job — 6,145 out of 12,463. Only about 38% got jobs that could have provided steady, full-time work.

The rest got placed in jobs that were either part-time or “temporary/seasonal” — the latter presumably referring to temporary or on-and-off jobs during periods of high-volume business like the holiday shopping season.

Wide Pay Range, Including Less Than Minimum Wage

While working, the parents got paid an average of $10.58 an hour — more than the District’s minimum wage, but less than its living wage, which is now $13.60 an hour and was less during the two prior years the audit covered.

The average masks a wide disparity in pay rates. A relative few jobs paid in the $21-$50 an hour range. A far greater number — nearly 1,590 — reportedly paid less than the District’s minimum wage.

The auditors suggested (not in the report) that contractors may have reported the minimum cash wage parents got when placed in jobs that employers chose to pay at the tip-credit wage rate.

But the District’s tip credit wage is lower than most of the subminimum wages indicated. DHS perhaps could explain, but hasn’t, though I asked.

Steady Work for Very Few

As of mid-October, 2,976 TANF parents were employed — about 48% of those who’d been placed. Only 770 remained in the jobs were they’d been placed for more than six months.

We see a drop-off beginning at the end of the first month. (The auditors don’t report a figure for parents who lost their jobs or quit sooner.) Their figures do, however, show that 835 parents didn’t have their jobs any more by the time the fourth month rolled round.

Whether they’d been placed in other jobs is an open question. Indeed, the job tenure figures may not tell the whole story.

DHS informed the auditors that an estimated 3,076 “customers” in the 60-month-and-over group had left the program — a majority, it said, because they began earning too much to remain eligible. No supporting data provided.

And the agency doesn’t know whether “customers” who did earn more than the minimal maximum for eligibility remained employed — let alone how gainfully — because it doesn’t track families once they leave the program.

More Knowns and Unknowns

First off, we should recall that the auditors focused solely on parents who’d been in the District’s TANF program for quite a long time — or had cycled in and out for even longer. Results for parents who had recourse to TANF because of some singular, temporary setback might be different.

On the other hand, the parents in the sample didn’t include those whom DHS had identified as having significant, ongoing health and/or personal barriers to work, e.g., alcoholism or drug addiction, PTSD due to domestic violence.

About 60% of the rest weren’t immediately work-ready, according to the agency’s assessments. It assigned them to contractors for further education and/or development of marketable skills. Fewer than 10% completed their programs.

Does this mean they were hustled into jobs they couldn’t keep because contractors get a bonus for placements? Or did they themselves get desperate because their very low benefits had shrunk — and were soon to disappear?

Did the fact they had to scramble every day to find a place for their family to spend the night — or some used clothing for their kids — make it just too hard to satisfy the work readiness requirements and, more importantly, their employers’ expectations?

Do we need a thoroughgoing, independent assessment of the TANF employment program? Sure does seem that way.


DC TANF Families Far Below Poverty Line, Even With Uncut Benefits

November 20, 2014

Shortly before the election, Washington Post reporter Rachel Weiner observed that none of the mayoral candidates had even mentioned “a dramatic change in the city’s welfare program that could drag many poor families into further distress.”

She was referring to the District’s decision to phase out Temporary Assistance for Needy Families benefits to families who’ve received them for a lifetime total of five years. The DC Council suspended the phase-out after the first cut — and for good reasons, as Weiner indicates.

But the cuts have gone forward again. They’re likely to leave more than 6,000 families with no cash assistance whatever come next September — unless the Council and soon-to-be Mayor Bowser agree to change the law.

But what about families whose benefits haven’t been cut? Not much of a safety net for them, as the Center on Budget and Policy Priorities’ recent state-by-state update on the benefits shows.

CBPP looks at the maximum cash benefit a single parent with two children can receive. That was $428 in the District when the Center did its analysis.

A provision in the latest Budget Control Act, i.e., the package of legislation that’s paired with the budget proper, provides for a cost-of-living adjustment this fiscal year, based on the Consumer Price Index.

That, I’m told, will boost benefits by 1.5% — just making up for what our three-person family’s benefit lost in value due to inflation during the July 2013-14 period.

The family will still have an income at about 26% of the federal poverty line. And it will be considerably worse off than three-person families were when TANF began.

Adjusting for inflation, the maximum benefit for our D.C. family has lost about a third of its real-dollar value. Losses were smaller in more than half the states.

And, as we all know, the cost of living here is higher than in most places. CBPP provides just one measure — the gap between the maximum TANF benefit for three-person families and the fair market rents the U.S. Department of Housing and Urban Development set for a modest two-bedroom apartment.

The pre-COLA maximum benefit for our D.C. family is 29.1% of the FMR for the apartment. In other words, the family couldn’t come anywhere near to paying for it, even if it spent its entire benefit on rent.

This is true for families in every state, but the rent shortfall is greater than the District’s in only two — Mississippi and Tennessee. Not, I suppose, states the District would choose as benchmarks.

Rankings of this sort aren’t nearly as relevant as the measures of how woefully inadequate TANF benefits are — and how more woefully in adequate they’ve become over time.

So far as housing is concerned, the maximum for our D.C. family would have covered nearly 44% of the FMR in 2000 — still a very large shortfall, but smaller because the benefit was worth more and rents in our area hadn’t skyrocketed.

Now, it’s true that some TANF families in the District have more cash income than the maximum benefit indicates because our local program exempts a fair amount of earned income when setting benefit levels.

Also true, however, as indicated above, that many families are receiving far less than the maximum. The phase-out alone has left some three-person families with as little as $152 a month.

Most, if not all of the families, however, receive a separate cash-equivalent benefit from SNAP (the food stamp program). Yet the cash value of SNAP benefits still leaves TANF families far below the poverty line.

CBPP shows this by combining the average monthly SNAP benefit for TANF families with the maximum the three-person family can get from TANF. With the two benefits, so defined, our D.C. TANF family was at 54.4% of the FPL in July.

But, says CBPP, this is probably an overstatement for many families because the average SNAP benefit it calculated assumes housing, plus utility costs high enough to qualify families for the maximum.

No such costs for the families in the DC General shelter, most of whom depend on TANF benefits. And lower costs, if any that families can claim if they’re doubled-up with accommodating friends or relatives.

There could be fewer homeless families if the District substantially increased TANF benefits now, as originally proposed, and modified the phase-out to preserve benefits for families who’d otherwise become destitute, even though the parents had done everything they were told to.

These could include families with a parent who’s working, but not able to earn enough to support herself and her kids and those with a parent who isn’t working because jobs she could qualify for are just too scarce.

And then perhaps there are parents who didn’t do everything they were told to because they couldn’t, e.g., those with certain intellectual disabilities or PTSD that caseworkers had failed to identify.

But such exemptions would still leave some families subject to phased-out benefits that would sink them even deeper in poverty than they already are — and less likely to achieve the self-sufficiency that TANF is supposed to promote.

How can you focus on preparing for — or seeking — work when you’re trying to figure out where you and your kids will spend the night or how you’ll feed them now that you’ve run through your monthly SNAP benefit?

Problems even for parents who are still within the rigid time limit now.

 


DC General Closing Plan Won’t Shelter All Homeless Families at Risk of Harm

November 13, 2014

I’ve been feeling I should say something about the Gray administration’s plan for closing the DC family shelter ever since it saw the light of day a couple of weeks ago. I haven’t because I’ve had trouble getting my mind around it.

Not altogether my fault. The plan, you see, isn’t really a plan. It’s more like a working paper — or a statement of preferences perhaps. These are certainly clear enough. But whether the next administration can translate them into a reality is at the very least questionable.

And in a couple of respects, I hope it doesn’t. But I’m getting ahead of myself. Here are the major issues, as I see them.

Should DC General Be Closed?

A rhetorical question. No one, I venture to say, thinks that DC General is an okay place for children and their parents to live, even temporarily. It’s too big — a “small city” Councilmember Graham called it.

It was never fully converted from the hospital it used to be — apparently because no one wanted to acknowledge that it was the replacement for the then-notorious shelter the former mayor felt pressed to close in 2007.

Its basic systems are seemingly beyond redemption — frequent heat and air conditioning outages, no hot water for long periods of time, elevators that break down — or in one recent case, get flooded. And the place is persistently infested by mice, roaches, bed bugs and the like. Moldy too.

In short, it’s shameful that a child would have to go missing to get District officials serious about closing DC General.

Where Would the District Shelter Homeless Families?

The Gray administration envisions smaller shelters scattered across the city. They would have to include play spaces for children and be near to public transportation and “community amenities [undefined].”

The administration would prefer buildings leased from private landlords because, it says, this option would be quicker and cheaper than renovating publicly-owned buildings or constructing shelters on publicly-owned land.

The latter would also require the District to pay for ongoing operating costs, e.g., utilities, maintenance. The preferred option would make private landlords responsible for these, as well as security systems, furniture and whatever renovations their buildings require.

Ideally, each building would have 40-50 units, though the plan allows as how some larger shelters might be okay. For the smaller shelters, it projects a $2,000 per month cost.

Now, why would an owner of a potentially suitable building in any of our high-rent, high-demand neighborhoods agree to lease it for a minimum of 10 years at a rate this low — or anything close?

And if one did, wouldn’t the NIMBY (not in my backyard) forces “come out of the woodwork,” as the Director of the General Services Department has predicted? One recalls what happened when the District considered putting a smaller shelter in soon-to-be Mayor Bowser’s ward.

So, says Aaron Wiener at Washington City Paper, the “available candidates” will instead probably be “boarded-up properties” in low-income neighborhoods on “the city’s margins” — far less convenient to public transportation and “amenities” than DC General.

What Would a Unit Be?

Well, I’ll tell you what it wouldn’t necessarily be — an “apartment-style” unit, which the District’s homeless services law requires for families, except when no such unit is available.

The Gray administration interprets this limited exemption to mean that shelter units the District has yet to lease or build don’t have to include a bathroom for each family or any place to prepare a meal. They apparently may be just a single room, where parents and children must sleep together — just as they must at DC General.

How Many Homeless Families Would Have Shelter?

The Gray administration wants the replacement shelters to have, in total, the number of units currently provided at DC General — and to close the shelter in one fell swoop “so as to avoid an unplanned shelter expansion.”

It’s not altogether clear how many replacement units there’d be, since the Department of Human Services has concluded that 40 or so units at DC General don’t meet the (minimal) criteria the court established when it ordered the agency to stop “sheltering” families in recreation centers.

What is clear is that there won’t be nearly enough replacement units unless the number of families needing shelter miraculously plummets — or the homeless prevention and rapid exit strategies the Winter Plan promises miraculously work much better than they’ve done to date.

The plan isn’t short on units because providing enough to meet the need would cost more than the District could afford. It’s “a clear philosophical stance,” says the Deputy Mayor for Health and Human Services.

And it’s based on a truly appalling ignorance — or worse — of what happens to homeless families when the District won’t provide them a safe place to stay. Senior policy advisor Sakina Thompson, who wanted even fewer units, says, “During the summertime, when shelter is not available, families find other means.”

Indeed, they do. They walk the streets looking for someone to take them in for awhile. They sleep in cars, if they have them, or at bus stops or on a church floor. They take refuge in a laundromat. Some presumably return to the abusers they’ve fled.

Whatever “other means” they find, they’re likely to have more and/or worse problems when the District must finally shelter them than they had when they become homeless.

Not so long ago, the District provided shelter year round to families who’d otherwise have no safe place to stay.

Mayor Bowser and the DC Council will have to decide whether to move forward with a plan that would intentionally replicate the crises that Gray and his people have used to justify barring the shelter doors, except when it’s freezing outside.

I’m hoping for a more compassionate — and policy-smart — philosophical stance.

 


We Don’t Know How Many DC Youth Are Homeless, But We Do Know Too Many

October 9, 2014

My last post focused on poverty among older teens and young adults, both in the District of Columbia and nationwide. Some, though far from all are homeless. Here’s what we know — and don’t — about the scope of the problem.

As you’ll see, we still don’t have a good fix on how many homeless young people are out in the world alone — those formally known as “unaccompanied.”

The U.S. Department of Housing and Urban Development reports that, on a single night sometime during January 2013, there were 40,727 homeless, unaccompanied youth in the U.S. These are all 18-24 year olds. Teenagers on the cusp of adulthood are lumped together with younger children. Far fewer were unaccompanied, according to the counts HUD tabulated.

Nearly half (48%) of the unaccompanied youth counted were unsheltered, i.e., spending the night in a car, public transit station or, in HUD-speak, elsewhere “not designed for or ordinarily used as a regular sleeping place for human beings.”

The District reported only six homeless, unaccompanied minors and said that all were sheltered. As some of you may recall, I questioned this figure when the results of the Washington metro area counts were first reported.

To HUD itself, the District also reported 158 homeless 18-24 year olds “in households without children.” Eighteen, it said, were unsheltered.

An additional 446 in the same age bracket and counted were in households with at least one children — presumably, in most cases, their own. Somewhat over half were in an emergency shelter — and none unsheltered, the report says.

If accurate, this is probably because the count was made on a freezing-cold night, when the District is legally obliged to shelter anyone who would otherwise have no safe place to stay.

What we know for sure is that more parents at the now-notorious DC General shelter are still in their teens or not much older. Last winter, nearly half there were between 18 and 24, according to the coalition that developed the roadmap for a better homeless family system.

Yet we also know for sure that both the national and the District’s figures are undercounts. This is partly because homeless youth — the unaccompanied, at least — are singularly hard to count.

But even the best count wouldn’t give us an accurate read because the definition of “homeless” that HUD must use — and therefore, the definition its grantees must use for their counts — excludes many youth, as well as older people whom most of us, I think, would consider homeless.

HUD has only recently begun requiring breakouts for homeless youth. And the latest posted reports are more detailed than those for the previous year. So we can’t trace trends. But we do have some evidence that the number of homeless, unaccompanied children and youth is rising.

The Department of Education, whose definition of “homeless” is broader than HUD’s, reports that the public school systems to which it had awarded grants for support to homeless students had 62,890 who were enrolled during the 2012-13 school year and with no parent or guardian looking out for them. This represents a 14% increase over the 2010-11 school year.

We don’t get a breakout for the District, alas. But we do find total homeless student enrollment figures in prior Education Department reports.

So we learn that the D.C. public schools reported 2,499 homeless students during the 2009-10 school year and 2,947 during the 2011-12 school year. This represents an increase of nearly 18%.

Though the upward trends indicated are probably accurate, the hard numbers are again almost surely undercounts.

For one thing, the homeless, unaccompanied students are only those who received services from grant-funded staff or activities. For another, the totals, including the District’s, tell us only how many homeless students school authorities could identify.

Homeless students, we’re told, are often reluctant to seek aid and hard for school authorities to identify when they don’t. They’re fearful of peer reactions, being put into foster care, etc. We can assume this is especially the case for those who are on their own.

And, of course, the Education Department’s figures don’t include youth who’ve dropped out of school — or those who’ve graduated and been unable to find jobs that would give them the wherewithal for rent.

In sum we seem to have better data on homeless children and youth than we used to — the unaccompanied cohort in particular. But we know they’re imperfect.

Here in the District, we may have better numbers fairly soon. The budget for this fiscal year includes $1.3 million for the End Homeless Youth Act — an optimistically titled bill based on recommendations by another coalition.

The bill requires the Department of Human Services to conduct “an extended youth count,” which, I take it, means something considerably more comprehensive than the one-night counts that have yielded such dubious figures.

But the bill itself called for $10 million in annual funding, reflecting what the coalition estimated the first year of its plan would cost. A million was for evaluation, including, but not limited to the youth count.

So it’s not altogether clear what we’ll have and when. Meanwhile, however, even the figures we have are plenty good enough to tell us that we’ve got a larger, more complex problem than our public agencies and the nonprofits they help support have the resources or the inter-connections to cope with effectively — let alone solve.

The Winter Plan for the upcoming season identifies 117 shelter beds specifically for young adults and 10 beds (no, this is not a typo) for unaccompanied minors.

And, as I earlier wrote, there’s no genuine plan for homeless families — thus none for the large number headed by parents in their late teens and early twenties. Setting aside the urgent shelter capacity issue, solutions designed for older people, e.g., rapid re-housing, may not be suitable for them.

Many challenges for the new administration. One can only hope it will be more concerned with meeting the diverse needs of its homeless constituents — even if that means spending more, as it probably will.

 

 


And We Thought DC Had a Homeless Family Crisis Last Winter

September 4, 2014

Last year, I remarked that the draft Winter Plan was notably sketchy on how the District would fulfill its legal obligation to protect families from exposure to “severe weather conditions.”

The Operations and Logistics Committee, which drafts the annual plans for the Interagency Council on Homelessness, decided against specifics that would minimize the foreseeable challenges.

And challenges there surely were — even greater than most think could have been foreseen. The Department of Human Services was caught off guard. Aaron Wiener at Washington City Paper recaps the results, as of mid-March.

Now we have another Winter Plan. And my heart sinks. Because it’s as clear as day — acknowledged, in fact — that we’ve got another crisis looming.

Like as not, a bigger crisis than last year’s and one that DHS is by no means prepared to cope with — at least, not in a way that would ensure homeless families a modicum of safety and stability. Here are the lowlights.

More homeless families expected. DHS will need to make an estimated 840 shelter and/or housing placements during the upcoming winter season. This represents a 16% increase over the number of placements made during the 2013-14 season.

Yet it’s 10% lower than the increase in the number of homeless families who sought help at the intake center between May and August. They couldn’t get into shelter then, but at least some will return as soon as the weather turns freezing-cold.

Not enough shelter units. The Operations and Logistics Committee again foresees that all — or nearly all — units at the DC General family shelter and those in smaller shelters around the city will be occupied when the winter season opens.

DHS will need “overflow capacity” by December, the plan says. This would probably be true in any case. But about 40 units at DC General may have to remain vacant because they fail to comply with the criteria the court established when it ordered DHS to stop warehousing families in recreation centers.

No plan for the overflow. The ICH has, for good and proper reasons, decided against any semblance of a shelter plan for families.

It instead recommends, among other things, that the Department of General Services prepare “an options analysis that considers different solutions,” e.g., use of District-owned buildings, short-term leases from private landlords, motels.

Not much time for General Services to do this — let alone for DHS to choose solutions and make the necessary arrangements, even if one of them isn’t re-purposing buildings.

Not enough money. The plan calls on the District government to acknowledge that “meeting the anticipated need for shelter will exceed currently available resources.”

The District should further acknowledge, it says, that additional resources will be needed to prevent adverse effects on other homeless services programs, especially those “designed to move families out of shelter.”

This was altogether foreseeable — and in fact, was foreseen by the DC Fiscal Policy Institute. Mayor Gray’s proposed budget included funds for only 150 units at DC General, rather than the 280 or so then available — and no funds at all for motel rooms. The DC Council went along.

Trust in performance improvements. “A major emphasis,” the plan says, “will be on enhancing system performance to both decrease the number of entries into the system … and accelerate exits out of shelter.”

As I (and others) have said before, DHS has had a hard time moving enough families out of shelter fast enough to free up anything close to the number of units needed. Various reasons for this — some of the agency’s own making, some not.

Resources committed to the Mayor’s 500 in 100 initiative may have speeded up the rate somewhat. But we’ve no assurance families will leave shelter even sooner this winter. “It is expected,” the plan says, “that placements from shelter will continue or exceed” the current monthly average.

Perhaps we should be at least as concerned about the other half of the emphasis — decreasing entries, i.e., keeping families out of the shelters.

The plan specifies two approaches. One is “strategic targeting of resources to prevent housing loss.” This presumably is a reference to the one-time funds some District residents may receive as emergency rental assistance. No problem here, except limited funds.

The other approach is casework and “housing stabilization support” for families who’ve been “diverted” from shelter. Translated into everyday English, the latter refers to resources that may enable families to stay where they are for awhile — mainly, if not exclusively in doubled-up arrangements.

The resources include cash or cash equivalents to give friends and relatives incentives for hosting homeless families, e.g., help with utility bills and/or food costs. DHS already provides such incentives and will have funds for more.

But the cost burdens of having extra people in the home are hardly the only reason doubled-up situations tend to be temporary. So diversion of this sort may, in many cases, merely delay “entries into the system.”

Looking beyond the the no-plan plan. The Homeless Services Reform Act charges the ICH to develop an annual plan “consistent with the right of clients to shelter in severe weather conditions, describing how member agencies will coordinate to provide hypothermia shelter and identifying the specific sites that will be used.”

The ICH has, in effect, said, “We can’t do that for homeless families. The money is not there.” This, to my mind, is altogether better than putting forth a plan that glosses over the acute problems the District’s homeless services programs will face.

“We face an enormous challenge,” said Washington Legal Clinic for the Homeless attorney and long-time ICH member Scott McNeilly. “If we don’t rise to the occasion, the consequences could be catastrophic.”

But ultimately “we” isn’t the ICH. It has no control over the budget or how available funds are used. It’s the Mayor and the DC Council who must “rise to the occasion.” And they’d better do it PDQ.

 


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

August 7, 2014

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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