NPACH Perspective: HUD NOFA Further Restricts
Communities and Excludes Populations
Ideas cannot digest reality-
Jean Paul Sartre
On March 21,
the U.S. Department of Housing and Urban Development issued
its annual Notification of Funding Available (NOFA), a set of
rules, regulations, and application procedures governing the
annual homeless assistance grants competition. Historically,
in applying for funds, communities are asked to rank local
needs and prioritize the gaps in resources available to meet
those needs through a local planning process known as the
Continuum of Care. Over the past few years, however, as a
result of the "chronic homelessness" initiative,
HUD’s design of the NOFA has increasingly undermined
local control, dispensed with Congressional action and
essentially legislated through the rule-making process.
Unable to successfully move the Samaritan Initiative through
the 108th Congress, the Bush Administration, via
HUD and the U.S. Interagency Council on Homelessness (ICH),
has now aggressively moved to impose the “chronic”
agenda on localities, rather than allow communities to
determine their own priorities based on actual need.
This almost exclusive focus on
“chronic” homelessness is pushing continuums to
seek funding for “chronic” projects- representing
30% of the total awards in 2004- at the expense of more
comprehensive strategies that place higher priorities on all
or other populations. For example, this year’s
application effectively removes all homelessness prevention
activities and limits a substantial “permanent housing
bonus” to projects exclusively serving the
“chronically homeless,” which must be ranked as the
number one priority on the locality’s list (HUD
defines the “chronically homeless” as an
“unaccompanied homeless individual with a disabling
condition who has either been continuously homeless for a
year or more or has had at least four episodes of
homelessness in the past three years”). The inevitable
result? While many communities have witnessed significant
growth in the scale and severity of homelessness among
families with children, unaccompanied youth, and disabled and
non-disabled populations that do not fit neatly into the
"chronic homeless" paradigm, these same communities
will be forced to overlook emerging needs in favor of a
narrowly constructed federal priority. And, with annual
appropriations at a virtual standstill and more dollars being
targeted and siphoned off for the “chronic
initiative,” funding for these permanent housing
bonuses, which typically go to the largest urban continuums,
will almost certainly come from the lower ranking
applications. Tragically and undeniably, the
Administration’s strategy of “ending chronic
homelessness” is now clearly being pursued and funded at
the expense of smaller communities and other homeless
populations.
This push to reorganize the homeless
grants by awarding application points for what HUD calls
“housing emphasis” is an especially cruel irony
given the concurrent budget cuts to housing for people with
disabilities, the elderly, persons with HIV/AIDS, and
continued attempts to dismantle the Section 8 program. In its
slick marketing of the President’s “10 year plan to
end ‘chronic’ homelessness by 2012,” the ICH
has attempted to sell communities on the premise that
“priority” doesn’t mean
“exclusivity.” We only wish this were true. But in
emphasizing “chronic homelessness” above all else,
the current policy has fragmented resources, pitted
populations and providers against each other, and attempted
to “end homelessness” with the resources only
intended to address a fraction of it. For its part, the
Administration appears impervious to criticism or sound
evidence, and seems determined to carry out a pre-conceived
policy of divestment and devolution (local plans to end
homelessness, for example), driven by an impossibly
inflexible and prescriptive grant process.
To make matters worse, it seems
there’s a new sub-pathology of the “chronic
homeless” population: “serial inebriates.”
That’s right. Serial inebriates. Talk about stigma.
Degrading labels notwithstanding, the Administration has
rolled out a new $10 million project to fund housing
assistance for persons who have been “on the street for
at least 365 days out of the past year, and [has] alcohol
problems.” While this is certainly a population worthy
of being helped, the selection criteria make satisfying the
grant almost impossible. The person served could not have
been in transitional or permanent housing at all during the
five-year period, presumably meaning they have cycled in and
out of jail. Further, projects applying for grant money need
to be located in a community with “at least 100 people
who are chronically homeless and unsheltered.” One has
to wonder how smaller communities and rural areas can hope to
compete, why there are so few treatment slots to begin with,
or why this money just as easily couldn’t have been
rolled into the general homelessness assistance account. But
then we need to remember that demonstration grant programs
often function a bit like professional wrestling. That is,
the winners are frequently pre-determined, but the match
makes for impressive choreography.
Perhaps the most disturbing aspect of
HUD legislating via regulation is that there is little
opportunity for meaningful input from the field. Instead, HUD
has effectively silenced alternative viewpoints by tying its
policies to funding streams that service providers
desperately need. Forced to jump through arbitrary hoops,
Continuums have little choice but to go along, thereby
"proving" that "chronic" homelessness is
the number one priority service need across the country. In
this perverse paper game, HUD actively redefines homelessness
and constructs the reality upon which it claims to base its
policies.
Will homelessness get worse before the Administration can "improve" the situation and declare victory? Any person with more than a passing grounding in history and policy, cannot possibly expect the current “chronic” strategy to “end” homelessness. Some will insist otherwise, but that is blind hope or willful delusion -- nothing more. There is too much at stake for advocates and service providers to be silent -- we must voice our concerns at the local, state, and national level, demanding responsible, inclusive, effective policymaking based on the realities of all our communities.
How has your community been impacted by the "chronic homelessness" initiative and the various requirements HUD has placed in the NOFA and funding applications? We are collecting experiences and concerns from across the nation in an effort to help decision-makers understand how what HUD puts on paper affects real people. Please send your anecdotes and analysis to NPACH at hudfeedback@npach.org.