ADVOCACY ALERT

NEOCH Opposes the Community Partnership to End Homelessness Act. Senate Bill 1801 (Reed D-RI).

 Summary: While there are a few improvements within the law, there are many large issues that are based on flawed science that will have a negative impact on our constituency.  We cannot support this legislation, and will not work on the local level for its passage.  As a member of the National Coalition for the Homeless, we made recommendations for how to improve this bill, and those were largely not added. The reality in Cleveland, Ohio is that homeless families are the fastest growing population, and we all struggle with trying to meet the needs of homeless families that dissolve while they wait for help.  This bill does very little to help these families and reduces the scarce resources for all homeless people to be used for single disabled and long term homeless individuals.  Too many of the decisions are now being made at the federal level, and the bill will not go very far to address the problems faced by individual communities.

 Specific Issues with this bill from NEOCH include: 

Authorized funding level is far below the need in our country.  We have seen such a sharp reduction in the number of affordable housing units in the United States, we need huge resources to meet the current need.

 We do not agree with the set-aside for permanent housing.  We believe that the permanent housing set aside should be additional funds.  The cost of building housing is so expensive that for many communities a 30% set aside for permanent housing does not even build a bathroom let alone an affordable housing unit.  The Federal funding is fragmented and divided among a large number of communities.  A set aside only makes sense if the money was pooled for an entire state.

We absolutely oppose the inclusion of the invasive HMIS system in any statutory language.  It is an unnecessary invasion of privacy that yields inaccurate statistics.  There are also no protections against HUD using these faulty statistics in the distribution of resources. 

We do not support the 25% cash match for Shelter Plus Care programs.  This is an unreasonable burden and is contrary to the theory behind the development of this program.  It is silly to keep urging all the services to reach out for mainstream resources.  They DO NOT EXIST!!!  In Cleveland, we wait 5 years to get someone on SSI.  We have strict time limits on families and cash assistance, and our Medicaid is for families only.  If there were mainstream resources available our shelters would use them.  They do not exist so HUD needs to pull its head out of the sand and help homeless people with real resources not sermons about fictitious funds. 

We do not support the limiting of services to only those deemed “allowable” at the federal level.  If Cincinnati determines that transportation assistance is essential and Cleveland says that voice mail is an essential service, we should not have to appeal to the HUD for an exemption.  There are such limited resources for homelessness, and this will only make it more difficult. 

Prevention is critical to the community and there should be additional resources for preventing eviction and preventing people from showing up at the shelter with rental assistance.  There should be additional funding available for this activity.  At this time, the current language strips funding for prevention from the ESG allocation and makes it difficult to fund through the CHAP or Continuum, because a community cannot supplant other programs.  

We oppose the “chronic” homeless initiative because it is based on flawed science.  The only way to make this work is to remove every homeless person who has been in the system for one year and place them in housing then mainstream resources will be available to serve the rest of the population.  By only removing a small number, we just create other long term homeless people who will be in the system for a long time, and we have to spend 4 or 5 times as much as we would spend on those who are not long term homeless.  We appreciate the expansion to families for permanent housing.  We do not support the limiting to only disabled head of the household for the long-term housing set aside.

The InterAgency Council on Homelessness has proven to be a waste of resources.  They have not marshaled other federal resources.  They have made decisions based on flawed research and keep pushing ideas that do not exist in the real world.  They do not need an increase in funding, because they do very little for us in the community except travel around defending the administration and their poor response to homelessness.   The ICH Director should be approved by the Congress upon appointment.  One example of the failure of this organization is why they have not consolidated the definition of homelessness in the federal system.  We also do not know why this was not included in the legislation to consolidate the federal definition to one or two instead of the eight that now exist. 

We support the requirement for timely approval of the grant, but we do not think that more funding should go into administrative costs or technical assistance.  We also believe that HUD needs guidance on cost allocation, and other issues that the programs have come into conflict with HUD over the years.   We recommend that the legislation direct HUD to follow OMB circular requirements regarding cost allocation.  There is a great deal of confusion in the community about what expenses are reimbursable especially in permanent housing projects and those should be clarified. 

We do not understand the rationale for rotating the board.  It is difficult to understand the funding process at this time without limiting the membership with a time limit.  We do support the requirement that the local funding board be evaluated on a regular basis.  The appeals process also needs to be specifically spelled out and clearly defined. 

Other issues missing from the legislation:

v     Some sanctions for cities that pass legislation directed specifically at homeless people (anti-camping, panhandling, loitering, etc. )  It is unreasonable for communities to receive money to help homeless people while criminalizing their existence at the same time.

v     There is no monitoring of the criminalization by cities.

v     The applicant for federal funds should be required to certify that they are not criminalizing homelessness.

v     The Department of Health and Human Services should develop a similar process to award funds for programs not funded by HUD.