On Tuesday, Coalition for the Homeless and The Legal Aid Society presented testimony to the NYC Human Resources Administration on two proposed rules that will restructure the City’s rent subsidies. Soon after Mayor de Blasio took office in 2014, he created a suite of rent subsidies to help individuals and families avoid or leave shelters. The LINC, SEPS, and CityFEPS vouchers have helped thousands of people find or remain in permanent housing, but the different eligibility criteria and implementation have proven to be confusing for voucher-holders and landlords alike, reducing the programs’ effectiveness. Last month, the City announced that it would consolidate these programs into a new streamlined voucher called CityFHEPS. The City also published a rule to replace the LINC VI subsidy with Pathway Home, which would enable people to stay with family or friends for up to one year while they continue to search for more permanent housing options.
While a streamlined process is welcome, the Coalition and Legal Aid pointed out in their testimony that the proposed changes, as currently drafted, have some serious flaws:
The Coalition and Legal Aid have repeatedly encouraged the City and State to address the root cause of homelessness – the lack of affordable housing – through proven-effective policies, including rental assistance, new housing development, supportive housing, and public housing (NYCHA). When Mayor de Blasio launched the initial City-funded rental vouchers (LINC) in the fall of 2014, it marked an important shift toward providing a greater range of housing options to New Yorkers in shelter, which were severely lacking at the time. However, as the LINC program grew and the City established additional rental assistance programs, shelter residents, staff, landlords, and advocates were often confused as to how they worked. A 2017 settlement in Legal Aid’s Tejada case expanded a similar State subsidy, which was renamed FHEPS, and increased the rent supplement levels, creating an additional layer of change.
We thank DSS for beginning the process of streamlining its vouchers. While the proposed CityFHEPS and Pathway Home rules may in some cases increase assistance and protections for New Yorkers at risk of entering shelters or already homeless, they also have the potential to exclude certain vulnerable populations and pose new challenges for implementation. Furthermore, the rules are not fully clear on some important points.
The primary issues raised in the testimony are:
- Maximum monthly rents should match fair market rent levels to allow families to find and maintain apartments and avoid entry into the shelter system.
- Homeless prevention avenues should be maintained, including for households who do not qualify for cash assistance and for those who do not currently have a lease.
- Limited eligibility excludes vulnerable homeless populations, such as youth and others who are homeless but not in contact with a Department of Homeless Services or Human Resources Administration shelter.
- Lease renewals should be required, as was the case in prior rent subsidies, to prevent people from cycling back into shelters.
- Ambiguities in the new rules should be clarified regarding safety and habitability assessments, program participant requirements and resources, the appeals process for people with disabilities, and other areas.
The full testimony can be read here.