A descriptive analysis of characteristics, challenges, and lessons learned related to ERA programs administered by Tribes and Tribal Entities
WASHINGTON, DC– The National Low Income Housing Coalition (NLIHC) announced today the release of a new report, Emergency Rental Assistance among Indigenous Tribes: Findings from Tribal Grantees. The report describes key characteristics and challenges of – as well as lessons learned from – emergency rental assistance (ERA) programs administered by Indigenous Tribes and Tribally Designated Housing Entities (TDHEs).
“Indigenous Tribes and TDHEs differ from other ERA grantees in important ways,” said NLIHC President and CEO Diane Yentel. “Unlike state and local grantees, tribal and TDHE grantees serve households across jurisdictional boundaries. They also have different housing needs, rental markets, and administrative infrastructures, resulting in unique barriers to ERA program implementation. By identifying these barriers – as well as best practices for overcoming them – this new research will help Indigenous grantees reduce housing instability in their communities.”
At the end of 2020, Congress appropriated $25 billion for the U.S. Department of the Treasury’s (Treasury) Emergency Rental Assistance (ERA1) program, including $800 million for Indigenous Tribes and TDHEs assisting low-income tribal members and residents of native lands. By the end of September 2021, tribal grantees had obligated $278.7 million – approximately 35% of their total allocation. At present, some Tribes and TDHEs have exhausted their initial ERA1 allocations and received additional funds, while others have not successfully utilized ERA despite increased housing instability in their communities.
The report shows that different patterns of ERA utilization were due in part to the varied sizes of grant allocations across Tribes and TDHEs, ranging from $64,000 to $93 million per grantee, with 57% of grantees receiving less than $1.5 million. The wide range of allocations across tribal governments led to disparities in administrative capacity: grantees with larger allocations were able to build the infrastructure and capacity needed to administer their ERA program and extend assistance to native households not living on reservations, while grantees with smaller allocations were unable to adequately increase capacity.
The report also highlights the importance of providing adequate federal guidance early in the ERA implementation process. Tribal and TDHE ERA program administrators identified initial Treasury guidance as impeding their ability to serve renters in need of assistance. Subsequent guidance resolved some of the confusion but created additional burdens by requiring administrators to review and revise program policies and, in some cases, reconsider applicant eligibility.
The report finds that Tribes and TDHEs were able to address ERA implementation challenges by adopting practices like documentation flexibility. For example, Tribes and TDHEs that used self-attestation, categorical eligibility, and fact-specific proxies to determine income eligibility lowered administrative burdens and better served low-income renters with limited access to technology and broadband services.
Emergency Rental Assistance among Indigenous Tribes: Findings from Tribal Grantees is available at: https://bit.ly/3r7KHcy
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About the National Low Income Housing Coalition
The National Low Income Housing Coalition is dedicated to achieving racially and socially equitable public policy that ensures people with the lowest incomes have quality homes that are accessible and affordable in the communities of their choice. NLIHC educates, organizes, and advocates to ensure decent, affordable housing for everyone. For more information about NLIHC, please visit www.nlihc.org.