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NLIHC Releases Report on the Use of Fact-Specific Proxy by Emergency Rental Assistance Programs

New report explores the use and impact of fact-specific proxy by nine ERA programs and makes suggestions about future implementation

WASHINGTON, DC– The National Low Income Housing Coalition (NLIHC) announced the release of a new report, Implementing Fact-Specific Proxy in ERA Programs: Key Considerations and Lessons Learned. The report explores how nine emergency rental assistance (ERA) programs have used fact-specific proxy—a method for determining income eligibility—to reduce barriers preventing renters from accessing ERA.

“Despite the availability of unprecedented funding, many extremely low-income renters have faced difficulties accessing rental assistance during the pandemic due to burdensome documentation requirements,” said NLIHC President and CEO Diane Yentel. “The new report shows that programs using fact-specific proxies have succeeded in reducing barriers to rental assistance and ensuring that funds are distributed to those renters most in need of support.”

When the COVID-19 pandemic led to wide scale job losses and housing instability, Congress passed legislation providing $46.55 billion in urgently needed assistance for low-income renters threatened with eviction. Yet many renters have faced barriers in accessing this assistance due to the requirement that they show proof of income, which can be difficult if not impossible for those without steady employment. Fact-specific proxies reduce these barriers by allowing programs to infer applicants’ incomes using “proxy” facts, such as the median income of an applicant’s census tract. Instead of being required to provide documentation proving income, applicants meeting proxy eligibility criteria need only self-attest to their household income.

The new report uses data from NLIHC’s ERA database and interviews with program administrators from nine ERA programs around the country to explore the implementation of fact-specific proxies. In addition to outlining federal guidelines regarding fact-specific proxies, the report discusses considerations for implementing proxies, the impacts of fact-specific proxies on program progress, and lessons that can be learned from recent implementation efforts. The report finds programs were motivated to implement fact-specific proxies to increase application accessibility, enhance program equity, and balance program flexibility and oversight. Fact-specific proxies helped programs decrease application processing times, increase fund disbursal, and decrease administrative burden for applicants.

The report also makes suggestions for programs considering using fact-specific proxy in the future. According to the report, programs should offer proxies as the initial option for income-eligibility determination to decrease the documentation burden for applicants and reduce staff time spent processing income documentation. Programs should also test potential proxies on a sample of applications or with administrative data prior to full implementation. By testing multiple proxies, programs can choose the most effective method for maximizing coverage of potentially eligible households.

The report urges programs implementing fact-specific proxy to share their stories publicly as well. By promoting innovations like fact-specific proxy, programs can help shift long-held beliefs about standard social service practices. The introduction of fact-specific proxy, for example, has already begun to shift perceptions about what level of participant documentation should be required when administering social service programs.

Implementing Fact-Specific Proxy in ERA Programs: Key Considerations and Lessons Learned is available at: 

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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