The Continuum of Care (CoC) program by the Department of Housing and Urban Development (HUD) is a cornerstone of the United States’ approach to combating homelessness. It’s designed to promote community-wide commitment to the goal of ending homelessness; to provide funding for efforts by nonprofit providers and State and local governments to quickly rehouse homeless individuals and families while minimizing the trauma and dislocation caused to homeless individuals, families, and communities; to promote access to and effective utilization of mainstream programs; and to optimize self-sufficiency among those experiencing homelessness. However, not all proposed legislative changes are seen as beneficial to this established system. The Homeless Children and Youth Act (S.256), for instance, has faced significant opposition from organizations deeply involved in homelessness advocacy, specifically due to concerns about its impact on the existing Continuum of Care program.
One prominent voice of opposition is the National Alliance to End Homelessness. Their stance against S.256 highlights critical issues surrounding the proposed expansion of the definition of homelessness and the potential strain on the CoC program. While acknowledging the importance of addressing the housing needs of families and youth, the Alliance argues that S.256, instead of offering solutions, could inadvertently weaken the very system designed to support the literally homeless. Their opposition is rooted in the belief that the Act, while well-intentioned, introduces changes that are ultimately detrimental to effectively tackling homelessness.
Overburdening the System: Increased Eligibility Without Resources
A primary concern raised by those opposing the changes proposed by S.256 is the dramatic increase in the number of individuals and families who would become eligible for HUD homeless assistance without a corresponding increase in funding. Currently, HUD’s definition of homelessness encompasses individuals who are unsheltered, residing in homeless shelters, or temporarily staying with others due to imminent displacement. S.256 seeks to broaden this definition to include individuals and families living doubled up with others for economic reasons, even if the displacement is not imminent.
This expansion, while seemingly compassionate, is viewed by opponents as problematic because it would significantly inflate the eligible population without providing additional resources to meet the increased demand. The existing homeless assistance system is already struggling, with a considerable percentage of the currently defined homeless population remaining unsheltered. Introducing millions of newly eligible individuals into this system, without a parallel increase in funding, would inevitably dilute the resources available for those who are literally homeless and in immediate need of shelter and support. The National Alliance to End Homelessness emphasizes that this would make it even harder for families, children, and unaccompanied youth with no place to live to access critical assistance.
Alternative Approaches: Focusing on Housing Solutions and Targeted Support
Instead of broadening the definition of homelessness in a way that strains existing resources, opponents advocate for alternative approaches that address the root causes of housing instability and provide targeted support to those in need. These alternative approaches are seen as more effective and sustainable ways to help families and youth facing housing challenges without undermining the Continuum of Care program’s ability to serve the literally homeless.
One key alternative is to directly address housing problems through increased investment in affordable housing solutions. Many families and youth who are doubled up due to economic hardship are not literally homeless but are facing housing affordability issues. What they need is assistance with housing costs, not necessarily homeless services designed for those with no shelter. Proposals such as expanding housing voucher programs, developing more affordable housing units, and implementing short-term housing subsidies or renter tax credits are seen as more effective ways to support this population and prevent them from falling into literal homelessness.
Another crucial area is to remove documentation barriers for those who are literally homeless and seeking assistance. Individuals who are doubled up and imminently facing displacement often encounter difficulties in proving their homelessness to access services. Opponents suggest loosening documentation requirements for this specific group seeking rapid re-housing or permanent supportive housing, while maintaining appropriate verification for those seeking shelter or crisis services.
Improving assistance in rural areas is also highlighted as a necessary alternative. Homelessness in rural communities often manifests differently due to a lack of shelters and formal homeless services. People in rural areas are more likely to be doubled up. The HEARTH Act already authorized a rural homelessness program, and its effective implementation by HUD is seen as a crucial step in addressing the unique challenges of rural homelessness within the existing CoC framework.
Finally, recognizing the special issues surrounding youth homelessness is essential. Unaccompanied youth under 18 are considered homeless regardless of how long they have been doubled up if they are in unsafe or unsupervised living situations. Opponents argue for revising the imminence of eviction requirement for these vulnerable youth and emphasize the need for a clear division of responsibility, with the Department of Health and Human Services (HHS) taking primary responsibility for unaccompanied minors, and HUD focusing on housing support within the CoC for older youth and families.
Costly and Questionable Data Collection Requirements
Another significant point of contention for those opposing S.256 is the mandate for communities to conduct an ongoing and costly assessment of the number of poor families and youth who are doubled up for economic reasons. This data collection requirement is viewed as burdensome, expensive, and of questionable value in effectively addressing literal homelessness.
HUD already requires communities to perform a bi-annual Point-in-Time (PIT) count of literally homeless individuals. However, the authorizing legislation for HUD specifically advises against including doubled-up individuals in this count due to the significant logistical and financial challenges associated with accurately counting this hidden population. S.256, in contrast, would require annual counts of doubled-up families and youth, placing a substantial and unfunded burden on local jurisdictions. Opponents argue that conducting such counts would necessitate expensive new censuses, surveys, or sampling studies, diverting resources that could be better used for direct services and housing programs within the CoC. Furthermore, given that the majority of doubled-up families and youth are not literally homeless, the necessity and utility of this extensive data collection effort are questioned.
Alternative Approaches: Enhancing Existing Data Strategies
Instead of imposing a costly and potentially inaccurate new data collection mandate, opponents propose enhancing and supporting existing data collection strategies to gain a better understanding of the broader housing needs, including those of doubled-up populations, without overburdening communities or distorting the focus on literal homelessness.
Leveraging the Census Bureau and its existing infrastructure is presented as a more efficient and reliable alternative. The Census Bureau already conducts the biannual American Housing Survey (AHS), which collects data on doubled-up populations at the Census Tract level. Opponents suggest making permanent the AHS Doubling-Up Module, which was tested in 2013 and designed to identify doubled-up households containing homeless individuals. Utilizing this existing data collection mechanism would provide valuable insights into the scope of the problem without requiring costly and duplicative efforts at the local level.
Supporting ongoing prevalence studies on youth homelessness is another recommended alternative. Several national research initiatives, including work by Chapin Hall, are already underway to improve the measurement of youth homelessness. These studies will provide more accurate data on the size of the population and refine counting methodologies. Investing in and utilizing the findings of these research efforts is seen as a more strategic approach to understanding youth homelessness than mandating potentially flawed local counts.
Finally, before implementing a universal and costly mandate, opponents suggest testing the viability of local surveys on a voluntary basis. HUD could offer communities the opportunity to voluntarily conduct counts of doubled-up youth and families, providing technical assistance and guidance on survey methodologies. Data from these voluntary counts, properly attributed, could be included in HUD’s Annual Homeless Assessment Report (AHAR), allowing for an evaluation of the viability and usefulness of such local data collection efforts before imposing a nationwide mandate.
Undermining Strategic Resource Allocation and Program Effectiveness
A critical concern for those opposing S.256 is its potential to undermine the strategic use of HUD resources and weaken the effectiveness of the Continuum of Care program, which has demonstrated significant success in reducing homelessness in recent years. The CoC program’s success is attributed to a combination of bipartisan support for evidence-based practices and outcome-based approaches at the federal level, coupled with innovative and tailored implementation at the local level. This effective federal-local partnership has resulted in tangible reductions in homelessness among families and single adults.
Opponents argue that S.256, by expanding the eligible population without additional resources and restricting HUD’s ability to set national priorities or prioritize evidence-based interventions, would dilute the impact of the CoC program. Watering down the program’s focus and strategic direction would make it harder to discern outcomes and could ultimately lead to a decline in federal support for these crucial efforts.
Alternative Approaches: Ensuring Strategic and Equitable Resource Distribution
Rather than dismantling the strategic approach of the CoC program, opponents advocate for ensuring that its strategies are equitable and do not inadvertently disadvantage any particular subgroup of the homeless population. This can be achieved not by removing HUD’s strategic controls but by refining them to ensure fairness and proportionality in resource allocation.
One key alternative is to employ proportionality in resource allocation, taking into account HUD’s primary focus on housing solutions. HUD resources should be distributed fairly across different homeless subpopulations, considering their level of need for housing interventions. Opponents argue that maintaining some degree of proportionality between resources and the needs of different subpopulations, while allowing HUD to retain strategic oversight, is the most effective approach. They note that while current resource allocation is generally proportional for most populations, including families with young heads of household, non-disabled individuals, including youth aged 18-24, may receive less than their proportional share.
Another crucial aspect is to ensure that other federal agencies assume their proper responsibility in addressing homelessness, particularly for specific subpopulations. Opponents emphasize that HHS should take primary responsibility for unaccompanied minor youth, allowing HUD to focus its CoC resources on housing solutions for older youth, families, and individuals within its area of expertise. This division of responsibility would ensure a more comprehensive and effective federal response to youth homelessness and prevent the CoC program from being overburdened with responsibilities that fall outside its core mission.
In conclusion, while acknowledging the serious challenges of child and youth homelessness and the need for a more precise understanding of its scope, particularly among doubled-up families and youth, organizations like the National Alliance to End Homelessness oppose the approach taken by the Homeless Children and Youth Act (S.256). They argue that the Act’s proposed changes to the definition of homelessness and data collection requirements would negatively impact the successful Continuum of Care program without providing effective solutions. Instead, they advocate for alternative approaches that focus on increasing affordable housing options, removing barriers to assistance for the literally homeless, enhancing existing data collection methods, and ensuring strategic and equitable resource allocation within the current CoC framework. The core of their opposition lies in the belief that diluting the focus of the CoC program and expanding eligibility without additional resources is not a productive path towards ending homelessness and may, in fact, hinder progress. The debate continues on the most effective strategies to address and ultimately solve the complex issue of homelessness among children and youth, with a clear need for solutions that build upon and strengthen, rather than undermine, the existing Continuum of Care program.
