RE: Definition of Chronic Homelessness, Docket No. 5573-P-01
Dear Secretary Donovan:
WASHINGTON, D.C. – June 4, 2013 – (RealEstateRama) — I am writing on behalf of the National Alliance to End Homelessness (the Alliance) to comment on the proposed rule published on March 27, 2013. Among other provisions, the proposal would change regulations defining chronic homelessness for all of the Department of Housing and Development‘s (HUD’s) homeless assistance programs.
The Alliance is a nonpartisan, nonprofit organization committed to preventing and ending homelessness in the United States. With its network of over 10,000 faith-based, nonprofit, and public sector partners, the Alliance is a leading voice on solutions to homelessness and has supported state and local entities to develop plans to end homelessness. Communities are implementing those plans using proven interventions that couple housing with an appropriate level of supportive services to help people remain permanently housed. With federal and local leadership, the Alliance is committed to ending homelessness once and for all in the United States.
Generally, chronic homelessness is characterized by the presence of two characteristics: frequent or lengthy episodes; and the presence of a disabling condition (mental or physical). The statutory definition sets out criteria for both characteristics. The disabling condition element is spelled out in detail in the statute and is not the subject of these comments.
The statutory duration/frequency element is met if the person has experienced homelessness either for one year or more, or 4 times in a 3-year period. The statute does not specify a time measurement for what constitutes a single episode. Under the interim rule currently in effect, 15 days or more can be considered an episode.
The proposed rule would change this significantly, requiring the cumulative length of the four episodes to be at least one year. Under such a standard, four episodes of equal length would be around 90 days per episode. However, the proposed rule also allows that a single episode could include a stay in an institution such as a jail or hospital for up to 90 days. HUD’s rationale is that the proposed definition “better targets persons with the longest histories of homelessness and therefore the highest level of need [and] allows for limited resources to be more effectively targeted…”
As a practical matter, the federal homeless resources at stake are subsidies for permanent supportive housing (PSH). Chronically homeless individuals and families often have significant disabilities of a behavioral nature, e.g., severe and persistent mental illness, that make it difficult for them to thrive in housing without ongoing supportive services. Evidence definitively shows that PSH is needed to solve their homelessness. While resource-intensive itself, PSH is shown to be cost-effective to serve this group over the long-term.
The Alliance strongly supports HUD’s work to direct PSH resources more appropriately to the most vulnerable individuals and families experiencing homelessness. We are concerned, however, that the proposed rule would screen out homeless people who research shows need and can benefit from PSH.
Early research in New York and Philadelphia, predating the current HUD definition, distinguished between frequent and long-term users of homeless shelters. Roughly equal numbers were found in each group. Significantly, differences in their health status were found to be small. Homeless people in both subgroups tended to have mental illness, substance use disorders, and medical or physical disabilities. Researchers further analyzed shelter utilization for both groups. Over a year, the frequent-user group averaged around 5 episodes averaging 54 days in length, compared to 2 episodes of around 281 days for the second group.
For the purposes of targeting PSH resources to homeless people with frequent or recurring episodes, these data certainly point toward a standard greater than the current 15-day minimum for an episode. A cumulative measure would serve well as a simple indicator of severity and hardship. However, we are concerned that the proposed change to adopt a cumulative length of 365 days over three years would disqualify a significant number of vulnerable homeless people from targeted PSH. The qualification that institutional stays are not counted in a single episode may mitigate this effect in some communities, and we appreciate this provision in the proposed definition.
The Alliance notes that under the proposed new definition, some communities would have very few people considered chronically homeless. The Alliance urges HUD to consider allowing more flexibility for communities making great strides in ending chronic homelessness, whose highest-needs cases fall short of the definition. In these communities, there may well be instances where a vulnerable homeless person does not quite meet the definition of chronically homeless, yet targeting PSH for that person would be appropriate and effective. The final rule should create a mechanism or process recognizing real priorities and allowing for exceptions when called for.
Finally, we note that the proposed definition would lead to less variation across communities. In addition to improved targeting, this would yield better national data about who is using PSH and other targeted resources. So too would data about the length of time between episodes, and where chronically homeless people are sheltered or housed during such intervals. In the future, if such evidence is available, HUD could consider further steps to encourage targeting of PSH resources, including refinements to the definition of chronic homelessness.
Vice President for Programs and Policy
May 28, 2013
Department of Housing and Urban Development
451 7th Street S.W.
Washington, DC 20410