NLIHC worked with the National Housing Law Project and members of the Housing Justice Network, a network of housing advocates and residents, to write a letter commenting on HUD’s proposed changes to the Moving to Work (MTW) demonstration program’s Annual Plan and Annual Report form, HUD form 50900.
NLIHC has long been concerned about the MTW demonstration because of the ability of MTW PHAs to impose time limits and work requirements, establish rent policies that cause housing cost burdens, and other actions that increase housing instability for residents.
The letter notes that because MTW is a demonstration program it is essential that HUD collect more information about MTW PHAs so that it can assess how those PHAs are using their funds and whether their activities are serving the statutory objectives of the demonstration. However, since the beginning of the program in 1996, HUD has not required the necessary data to evaluate the demonstration. While the proposed revisions to form 50900 do provide better instruction and guidance, they still fall far short.
In reviewing the purposes and objectives of the MTW demonstration, the most critical elements HUD should address include:
- Ensuring meaningful resident outreach and engagement,
- Ensuring that the statutory objectives of increasing housing choice and economic self-sufficiency are achieved,
- Ensuring that 75% of the families assisted are very low income (below 50% of area median income),
- Ensuring that substantially the same number of low income people are served as were served before the demonstration,
- Ensuring that the PHA maintains a comparable mix of families served (by family size) as were served prior to MTW,
- Documenting how each MTW PHA has used the funds made flexible under the MTW program (Capital Fund dollars can be used for vouchers or for operating expenses, for example), and
- Ensuring full compliance with civil rights laws.
The comment letter provides suggestions regarding ways form 50900 should guide PHAs to undertake greater and more meaningful resident outreach and engagement. Advocates recommend requiring PHAs to provide more detail, including:
- The nature of the public housing stock, voucher units, and other assisted housing stock,
- The income characteristics of the people served,
- The demographics of those served, such as race, ethnicity, disability, and familial status so that a fair housing assessment can be made,
- The characteristics of people on the wait list, and
- The impact of any rent reform.
The MTW comment letter is at: http://www.nlihc.org/doc/MTW_Comment_Letter_7-15-11.pdf
More information about the Moving To Work Demonstration is on page 149 of the 2011 Advocates’ Guide, http://www.nlihc.org.