On March 30th the U.S. Senate Housing and Transportation Subcommittee held a hearing on S. 1801, the Community Partnership to End Homelessness Act, a bill that would reauthorize the HUD McKinney-Vento homeless programs. Over the past year only a small number of groups have been invited to work with Sen. Jack Reed’s (D-RI) office in drafting the bill, and an equally small number were asked to testify in person to members of the subcommittee.

Regrettably, this process has severely limited a full discussion or adequate representation of all points of view. Given what is at stake, it is crucial to make your voice heard. The National Policy and Advocacy Council on Homelessness (NPACH) and the Western Regional Advocacy Project (WRAP) strongly encourage individuals and organizations to send letters and submit comments on proposed changes in federal homeless policy to their Senators and members of the subcommittee.

For local organizations, it is especially important to highlight homelessness issues in the community and offer how proposed changes made by CPEHA would affect them. Contact WRAP to get contact information for Senate offices and subcommittee members.

In the time since S.1801 was introduced to the US Senate on September 29, 2005, we have been educating ourselves on its content and potential ramifications. Prior to its introduction in the Senate and referral to committee, we had not seen drafts of the bill nor had we been advised on the recommendations made to you during the drafting process, so it has been a game of catch-up. Now that we’ve had time to review the proposed legislation and conduct outreach to those affected by it, we would appreciate the opportunity to let you know how we think this bill could be effective in contributing toward its stated goal of eradicating homelessness in America, and to outline the points that we think could have serious negative impact. We certainly appreciate your efforts to increase HUD budget authority for homelessness assistance to $1.6 billion; as ranking minority member of the Subcommittee on Housing and Transportation, we are confident that you know that even $1.6 billion in homelessness assistance is insufficient to compensate for the sixty four per cent (64%) cut in HUD affordable housing assistance that we have experienced since 1978, as well as the over 100,000 Public Housing units we’ve lost since 1996, but $1.6 billion is $300 million more than is currently being spent and we respect and appreciate your efforts in pushing to make that happen.

It is our understanding that you have been working with DC-based national organizations in crafting this legislation, but we have seen no evidence that outreach to McKinney-Vento contractors and Continuum of Care organizations—in our region, and indeed anywhere in the country—was performed as part of the process. We have conducted outreach to some of those potentially affected by this bill, and we would like to offer the input we’ve gathered. This is neither in support of nor opposition to the bill, it is merely the direct input we have received from the organizations who would be expected to implement and conform to the regulations and funding priorities of S.1801, as well as those to whom they provide services.

We are aware that there is a subcommittee hearing on this bill on March 30, 2006. As representatives of service providers in rural, urban, and suburban communities throughout the U.S. who had no opportunity to conduct outreach on this bill prior to October, 2005, we hope you will receive this constructive criticism in the spirit in which it is intended. We know you’re trying to help the situation, but there are some areas of this bill that demand further consideration.

1. The 25% cash match requirement is a practical impossibility for many if not most of the small and rural homeless assistance programs. S.1801 could in fact have the effect of closing down many homelessness assistance programs by creating a disincentive for communities to apply for assistance. Currently, many agencies partner to provide in-kind services to meet the match requirements set forth in McKinney. Many agencies and organizations simply do not have access to the kind of capital that S.1801 would require of them in order to receive funding. They would be out of the running even before the annual competition began.
2. The Collaborative Applicant system defined in the current bill seems to be more weighted toward short-term plan writing than toward developing an ongoing system of monitoring and compliance. The input that you get from community groups when drafting an outline, as opposed to the due diligence that is required for ongoing compliance and implementation, requires completely different skill sets, different confidentiality guidelines, different staffing patterns, and different levels of ability for ongoing participation than those reflected in the structure spelled out in S.1801[MC1].[MC2]3)
3. We have been unable to find any local community support for the 30% set-aside provision for supportive housing. While we recognize that several national organizations have encouraged your office that this provision is sound, we have not identified any local Continuum of Care boards or homelessness assistance organizations in support of that position[MC3].
4. We have found almost universal support for amending the HUD definition of homelessness to include people who are sharing the housing of others due to loss of housing, economic hardship, or similar reasons (commonly referred to as “doubled up”), and people living in motels. This broader definition more accurately reflects the reality of homelessness in urban and rural areas. It is also particularly sensitive to the needs of families with children and youth on their own. Such a definition would bring the HUD subtitle of the McKinney-Vento Act into closer alignment with the U.S. Department of Education subtitle, as well as with the homeless programs administered by the U.S. Department of Health and Human Services.
5. S.1801 will require Collaborative Applicants to engage and participate in zoning and regulatory bodies without mandating any authority to influence the processes or decisions of these bodies. In areas where balance-of-state applications are the predominant McKinney funding streams, this is a particularly relevant issue.(1)

Since McKinney-Vento was enacted in 1987, it has always required—through all of its changes—that a gaps analysis be done so that the need for services versus the availability of services was clearly documented. In conducting outreach on S.1801, we have heard from community after community that the results of the still-required gaps analysis work has become less and less relevant to those communities’ ability to access federal funding. It is our strong recommendation that the priorities identified in the process of conducting gaps analysis be allowed, with proper documentation, to drive the bonus points and bonus funding for local communities. The more a local community can document the gaps in services and develop proposals to fill those gaps, the more bonus points they should get. The regulatory pattern of HUD has been to predetermine bonus points and funding based on their priorities, which has made local gaps analysis virtually irrelevant. Communities are looking for flexibility in funding streams to meet their most urgent needs, not for the ICH or HUD to predetermine what their needs are.

In the very short amount of time we’ve been working with your staff to create the outreach tools necessary to gather input from impacted organizations and individuals, we have unfortunately identified several areas where this bill, regardless of its good intentions, can have some severely negative impacts. We encourage your office to allow more time to hear from the field, so that we can craft a CPEHA bill that we all can implement and support; if we can’t implement it, we certainly can’t support it. Many of our rural and small programs have stated unequivocally that the passage of this bill would wipe them out, and we know and we trust that this was never your intent.

NPAC and WRAP

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