HUD’s New Definition of Homelessness

By Ellen Kriz

The Department of Housing and Urban Development (HUD) published a new definition of homelessness in late 2011, and it went into effect January 2012. The definition follows certain regulations and guidelines mandated by The Homeless Emergency Assistance and Rapid Transition to Housing (HEARTH) Act which was signed into law by President Obama in 2009. The HEARTH Act is basically a revision of the McKinney-Vento Homeless Assistance Grants, so it changes some of the policies of Continuum of Care (CoC) and Emergency Solutions Grant (ESG) programming. HEARTH focuses on the needs of families and children and prioritizes preventative care or permanent supportive services for the homeless.

In addition to new record keeping rules to ensure thorough and accurate documentation, HUD specified some of the HEARTH Act’s more general guidelines to develop the new working definition of homelessness. The act also carved out the basics for the most drastic change to the definition—a new category of homelessness. Those who experience persistent housing instability (category 2) are now considered homeless. HUD interpreted the guidelines set out by HEARTH and defined housing instability very strictly. Youth under 25 or families with children who have not had permanent housing in 60 days, have moved two or more times in that time frame, and who have various barriers to stability or employment such as an abusive past, chronic disabilities, or illiteracy (among others) are now eligible for assistance that was previously unavailable. They must also be defined as homeless under another federal statute like the one used by the Department of Education to qualify as homeless due to persistent housing instability. This new homeless demographic will be added to the three previously existing categories: those lacking adequate nighttime residence, imminently losing nighttime residence, or fleeing/ attempting to flee domestic violence.

In Cleveland, the director of the Office of Homeless Services, Ruth Gillett, said that CoC providers in Cuyahoga County focus on assisting homeless individuals under categories 1 and 4 (no adequate nighttime residence and fleeing domestic violence). She commented that “these are the highest need households for homeless funding since they are in fact homeless. This targeted population, while not small, represents fewer households than would qualify under categories 2 and 3. Given the very limited resources, serving category 1 and 4 households makes the most sense.” And since CoC programs in the area targeted these individuals and households for services previously, the new definition does not require the Office of Homeless Services and other providers to adjust their policies.

In all, the new definition expands the population that is eligible for homeless assistance. Most groups do not expect that this will impact current programming significantly, just as most Cleveland programs do not have to make any major changes to who they serve. As HUD continues to define the parameters of the HEARTH Act, however, CoC’s may be encouraged or discouraged from serving certain populations. The HEARTH Act does allocate funding based on the performance of the programs that apply for money, so prioritizing homeless categorized under permanent housing instability, for example, could jeopardize or enhance performance records and motivate program directors to adjust policies accordingly. Even so, it is unlikely that the new definition will disrupt any of the important services that homeless assistance currently provides. It simply offers CoC and ESG programs the opportunity to reevaluate who and how they serve and reorganize administration procedures to ensure that HUD’s new policies are implemented efficiently.

Copyright  Cleveland Street Chronicle  July 2012   NEOCH