[Hpn] Washington, DC - NCH Develops Comments on HUD Strategic Plan - National Coalition for the Homeless - December 11, 2002

H C Covington H C Covington <hccjr@bellsouth.net>
Sun, 22 Dec 2002 19:35:26 -0600

HUD Releases Five Year Update to Strategic Plan 2003-2008

National Coalition Offers Comments on HUD Plan
By Staff Writers - National Coalition for the Homeless - December 11, 2002

Washington, DC - The root causes of homelessness in the United
States are extreme poverty and lack of affordable housing.

Therefore, in reviewing the FY03-08 strategic plan, NCH is
extremely perplexed that HUD has subsumed its approach to
homelessness under the programmatic goal of "Strengthening
Communities" rather than under "Promoting Decent Affordable

We are also very troubled that HUD views the "availability of
low-cost housing as a factor beyond HUD's control" (p.47). To be
sure, homelessness is the tragic end point of failed housing

People become homeless for a variety of reasons, but the lack of
affordable housing underlies the issue.

Therefore, it is critical that any efforts to end homelessness
are premised on a strategy to create, preserve, and rehabilitate
affordable housing for people with low or no income.

Objective C.3: End chronic homelessness in ten years. P.36

As NCH has previously stated, we oppose the use of this term, as
it characterizes people experiencing homelessness as

Furthermore, HUD Secretary Martinez agreed not to utilize this
terminology in a February 2002 meeting with our Executive
Committee, but this language and policy focus remains included in
the 2002 SuperNOFA, the HUD Strategic Plan, the FY 03 Budget and
as the focus of a recently announced $35 million
multi-departmental initiative.

We have several serious concerns surrounding this policy focus,
including one around the definition currently being utilized. The
definition of chronic homelessness applies only to single adults
who have severe disabilities and have been continually homeless
for one year or more, or have recurring episodes of

While this is an extremely important population to serve, this
definition excludes even families who have experienced long term

We strongly urge HUD to incorporate a more representative range
of populations experiencing homelessness in the formation of its
strategic planning and policy formation.

Most people experiencing even long term histories of homelessness
move in and out of shelters, living doubled up, outside, or in
cars or abandoned buildings. As soon as they are doubled up they
no longer meet HUD's definition of homelessness.

It would be virtually impossible to document where people have
been over the last year, or to provide HUD the documentation that
people meet the time criteria.

Furthermore, many people who have had multiple experiences and
long periods of homelessness are not willing to admit that they
may have a disability or to see a medical professional due to
previous experiences with health providers.

Unless people are willing to admit and get a diagnosis or a
statement from a qualified professional that they are emotionally
impaired they will not meet this definition, no matter how long
they have experienced homelessness.

The process of a community developing a plan to end homelessness
for people with disabilities and long histories of homelessness
should be: first to prevent people from getting to that point,
second to utilize the McKinney-Vento resources to intervene and
help people access resources prior to reaching a year, and to
design any/all programs for this population as well as all people
experiencing homelessness with significant input from the people
who will be utilizing the programs.

Means and Strategies, p. 40-42

p.40- "Streamline the consolidated planning process, making it
more results-oriented and useful to communities"

NCH supports coordination with other planning processes,
especially with the Continuum of Care. We request that there be
severe penalties in the Con Plan for any community that
criminalizes homelessness.

p. 41- 'The Department has and will continue to ensure that at
least 30 percent of all available homeless funding is awarded for
permanent housing'.

NCH supports the development of permanent housing for all people
experiencing homelessness.

However, we believe the HUD McKinney-Vento resources should be
utilized for homelessness prevention, addressing emergency needs,
and act as a transition to increases in permanent housing
resources in mainstream programs through HUD and USDA, not as a
replacement of those resources.

HUD should honor the local decision making process ("Given the
variety of individual needs and locally available resources, each
community can best design its own strategies to help each
homeless person and family achieve permanent housing", p. 37) and
not skip priorities in communities.

The required 30% set-aside has already forced numerous
communities to cut funding for programs that serve families,
children, and other non-disabled populations.

Long-term homelessness cannot be prevented if HUD skips over
projects that will intervene and end homelessness for individuals
and families before they are homeless for a year.

p. 40-41 '[M]ake Federal mainstream supportive service programs
more accessible to homeless people'.

It appears HUD is assuming that Continuums of Care (CoC) have
some control over mainstream systems, and that there are enough
resources in those programs to address the service needs of
people experiencing homelessness.

Furthermore, HUD is assuming that all people experiencing
homelessness qualify for these programs.

Unfortunately, most mainstream programs have never even heard of
the CoC process; they are already being fully utilized by
eligible populations; and certain specific populations of people
experiencing homelessness do not qualify for some of these
mainstream programs.

NCH encourages Congress, HUD and HHS to establish a bonus to
communities that utilize mainstream funds for services with
additional resources through HHS.

We are pleased that the Interagency Council on Homelessness is
coordinating among the Department of Housing and Urban
Development, the Department of Health and Human Services, and the
Department of Veterans Affairs in offering $35 million in grants
to communities for permanent supportive housing initiatives.

The coordination among these and other agencies is essential as
we work together to end homelessness. This opportunity for
communities to submit a single proposal to these three agencies
satisfies a long-standing request of many communities.

p. 41- "HUD also plans to carefully scrutinize the policies of
its mainstream housing programs to determine whether additional
mainstream housing resources can be brought to bear."

We applaud this decision as HUD McKinney-Vento funds alone are
not designed to nor can they meet the permanent housing needs of
people experiencing homelessness.

To truly address the permanent housing crisis in the nation,
including the needs of people experiencing homelessness, HUD
should work with Congress and the Administration to increase
funding for and strengthen Section 8, public housing, CDBG, HOME,
Section 202, Section 811, and HOPWA programs as well as create a
National Housing Trust Fund, rather than set-asides on HUD
McKinney-Vento programs.

p. 42- "Assist Communities in developing the Congressionally
mandated Homeless Management Information System."

We oppose the use of any HUD McKinney-Vento funds or any other
housing funds to be utilized for HMIS. Communities are being
forced to make choices between housing, support services and HMIS

HUD should support HMIS funding as an eligible administrative
activity independent and exclusive of housing and support
services. Communities or projects applying for HMIS funding
should receive additional administrative funding over and above
baseline administrative allocation.

HUD needs to immediately provide CoCs with the data fields they
will be requesting and clear direction in regards to data privacy
and confidentiality and legal requirements in the collection of

The information collected should only be utilized in an aggregate
format to analyze systems. Some very expensive and ineffective
systems, which violate confidentiality and data privacy, have
already been developed to meet the HMIS mandate. HUD should not
penalize a community that does not have the capacity and/or
resources to establish HMIS.

p. 42- "HUD will inaugurate targeted technical assistance
specifically tailored to organizations serving homeless persons
living in Colonias areas."

Colonias are historically underserved areas and we hope the
decision to target technical assistance represents renewed
attention and increases in all forms of housing and services

NCH is eager to see this undertaking coordinated with the Housing
Assistance Council and USDA efforts. We are also interested in
hearing how HUD's definition of homelessness will fit within this

Performance Measures, p.43-44

Reduce Homelessness

"Counting both homeless individuals and families is expensive",
p. 44

Homelessness will not be reduced through counting individuals and
families. While data may serve as a guide for program development
and certain outcome measures, only when housing, health, living
wages, income supports and civil rights protections are made
available to people living in extreme poverty will there be a
significant decline in the number of people experiencing

The Number of chronically homeless individuals declines by 50
percent by FY 2008

As HUD itself acknowledges, the arbitrary-definition applied to
this population seems to make it impossible to measure a 50%
reduction goal. Instead, HUD should focus its efforts on the
prevention of homelessness and the creation of affordable housing
for families and individuals alike.

External Factors, p. 47


"Success in helping the homeless achieve housing stability is
affected by a variety of factors beyond HUD's control…the
incidence of homelessness is driven by macroeconomic forces such
as…the availability of low-cost housing," p. 47

We applaud the recognition of the multiple factors that cause and
sustain homelessness, and the reinstatement of the US Interagency
Council on Homelessness to more effectively coordinate a
multi-departmental response.

HUD, however, needs to recognize the nation faces a severe
housing crisis that directly contributes to homelessness and
exert leadership in the effort to increase the availability of
low-cost housing, not abrogate that critical role and

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