The Department of Housing and Urban Development has issued new rules for the distribution of funds to the shelters. These were issued in July 2012 and the comment period was extended until November 16, 2012. It is important to add your own local statistics, experiences, and examples to influence the thinking of the officials at HUD in Washington. We have a couple of pages of comments that NEOCH will be submitting here under September 2012 on our advocacy page.
The docket number is FR-5476-N-02 and the title is Homeless Emergency Assistance and Rapid Transition to Housing: Continuum of Care Program; Interim Final Rule. You just need to enter one of those pieces of information on the website www.regulations.gov. The Northeast Ohio Coalition for the Homeless is urging local advocates, social service providers and those experiencing homelessness to submit comments on these new rules. We believe that these new rules will guide the decisions made on the allocation of funds for the next decade. It is likely that these rules will set the course and composition for the local boards for the next dozen years. These rules will shape the types of programs that get funded at the local level and will shape the involvement of homeless people in these decisions. NEOCH believes that as these rules are enacted local communities will be forced to change the way people access shelter and are discharged from the shelters.
We urge you to include your own comments, activities and examples to add to the recommendations that we made. The compete rules can be found in the Federal Register for July 31, 2012 Part II under Department of Housing and Urban Development. There is a good summary of the new rules on the National Alliance to End Homelessness’ website here http://www.endhomelessness.org/library/entry/summary-and-analysis-of-the-interim-coc-rule. We believe that HUD officials will listen to local caretakers of the homeless population and your concerns over these new rules, and we hope that they will listen to those who have stayed in the shelters. If you don’t have time to add your own comments, please feel free to cut and paste our comments and just add the name of your agency at the beginning of the document. Feel free to call or e-mail if you have questions.
Some of the improvements in the legislation include the requirement that transitional shelters must provide the resident a lease. It exempts domestic violence programs from submitting client data to the County shelter wide databases. It bars families from being split up when communities offer shelter especially in prevent male children between 12 and 17 years old from staying at a family shelter. It eliminates the definition of homelessness as over 15 days, which presented all kinds of problems for shelters.
Some of the areas of concern for NEOCH include:
- The definition of transitional shelters should clarify that the lease should be enforced by the court or the person should be transferred to an appropriate facility, and not made homeless again if they fall off the wagon.
- Those who enter a transitional shelter should be allowed to transfer to a permanent supportive housing project.
- HUD funded shelters should follow all fair housing rules for entry and discharge especially.
- We believe that the local boards that decide on how federal dollars are distributed should include more than just one token homeless person.
- We urge HUD to require a law be passed to regulate the minimum standards at the local level. This should regulate the entry process and discharge procedure for shelter.
- We also believe that HUD needs to take a second look at the laws regarding privacy in the HMIS regulations.
- We believe that HUD should require the local agencies and the local government oversight authority to post information on publicly available websites about accessing these resources. This is especially important now that we have limited resources such as the homeless prevention/eviction diversion funds. It is so difficult for homeless people to find out about these resources, and so HUD should mandate that the information is posted on a publicly accessible website.
- We believe that there should be some rules issued by HUD regarding the trend toward centralized intake and especially strong oversight of these projects so that people are not denied shelter.
- Finally, we believe that HUD should develop some rules for oversight of the permanent supportive housing projects locally.
Again, check out our advocacy alert on our website for more information.
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