September Data Show 40% of ERA1 Allocation Disbursed, Many Grantees Remain at Risk of Funding Recapture and Reallocation

The U.S. Department of the Treasury released updated Emergency Rental Assistance (ERA) program spending data through September 30, revealing that an additional $2.6 billion in ERA1 and $354 million in ERA2 funding were spent in September, bringing total ERA spending to $10.3 billion. After a significant increase in spending from July to August, grantees spent only slightly more in September than in August. Monthly spending over time reflects significant progress in ERA spending by grantees, though many programs have yet to incorporate flexibilities to accelerate funding distribution and are at risk of having funds recaptured and reallocated to other grantees.

State grantees, whose allocations account for $17.7 billion of ERA1, spent 38% of their funding by September 30, though spending levels vary widely. New Jersey, the District of Columbia, New York, and Illinois have spent 90%, 89%, 83%, and 75% of their allocations, respectively. Many other states continue to fall behind, with 18 states having spent less than 15% of their allocation by the end of September.

Localities continue to spend their ERA1 funding more quickly than states. Local grantees reporting spent 60% of their total ERA1 allocations by the end of September. Approximately 79 localities have spent more than 80% of their funding, and 186 have spent more than 50%. Many large cities and counties are among those who have distributed most of their ERA1 funds. Cities and counties that have spent at least 90% of their allocation include Los Angeles, CA, Houston and Harris County, TX, Charlotte, NC, San Diego, CA, Philadelphia, PA, Honolulu, HI, Miami-Dade County, FL, and Nashville, TN. Forty-one localities have spent less than 15% of ERA1 funds. 

Treasury has also begun reporting preliminary data on ERA2 spending. By the end of September, $354 million of ERA2 funding was paid to households, approximately 2% of the ERA2 allocation. Among the 400 grantees, approximately 85 have started spending their ERA2 funding. Not all grantees, however, have spent down their entire ERA1 funding, indicating that some programs may have switched to ERA2, which allows grantees additional flexibilities.

Per Treasury guidelines, grantees were expected to have expended at least 30% of their ERA1 funds for financial assistance by the end of September. Over a quarter of ERA1 grantees—including 32 state and 80 local grantees—had not yet reached the 30% expenditure ratio threshold by the end of September and are at potential risk of fund recapture if they do not adequately increase their spending. Not all these programs will have funds taken away, however, because of methods for mitigating recapture instituted by Treasury.

As of September 30, 63% of state grantees had not yet reached a 30% expenditure ratio. States with large renter populations and low distribution rates are particularly concerning. These include Arizona, Georgia, Tennessee, and Ohio, which had expenditure ratios of 5%, 9%, 10%, and 14%, respectively, by the end of September. Twenty-one percent of local grantees also remained below the 30% threshold at the end of September. Several large cities and counties have spent very little, including Portland, OR and Dallas County, TX, which had expenditure ratios of 17% and 21%, respectively. NLIHC tracks ERA spending on the ERA Dashboard and Spending Tracker. This tracking integrates Treasury data with real-time data from program dashboards and program administrators to provide a closer estimate of how much ERA funding has been obligated to date.

Download Treasury’s September ERA data at: https://bit.ly/3GzaSP4