The NLIHC-led Disaster Housing Recovery Coalition (DHRC) and the National Housing Law Project (NHLP) submitted a comment on September 16 in response to suggested changes regarding the Rapid Unsheltered Survivor Housing (RUSH) program issued by HUD in the Federal Register. RUSH is a first-of-its-kind program meant to address the needs of the lowest-income survivors and those from the most marginalized groups, who are often hardest hit by disasters and left with the longest paths to recovery. Deployed in similar ways to HUD’s Emergency Solutions Grant (ESG) program, RUSH aims to “help communities provide outreach, emergency shelter, rapid re-housing, and other assistance to people experiencing or at risk of homelessness who are in a disaster-affected area but who cannot access all services provided by FEMA programs.”
In the comment, the DHRC expressed its appreciation to HUD for creating the RUSH Program. The program is sorely needed because, despite the clear need, initial recovery efforts undertaken by the Federal Emergency Management Agency (FEMA) frequently leave survivors without the assistance necessary to recover fully and render communities less resilient to future disasters – especially individuals experiencing homelessness.
The RUSH program represents a major shift in how HUD views its role in the disaster response process. Yet while the agency’s effort to address the gaps in the current system by providing fast, low-barrier access to housing through its RUSH program is laudable, realizing the program’s full potential requires improving how it is put into practice. The comment outlines multiple solutions for improving the program, including requirements for robust public participation, ensuring that jurisdictions have the tools necessary to address the unique needs of those with the lowest incomes in the aftermath of disaster, triggering RUSH funds to be sent to communities earlier, aligning program timing requirements, and providing up-front funding for programs instead of reimbursements.
The suggestions included in the comment draw upon the significant expertise of the DHRC, and particularly the lessons learned following the first deployment of the RUSH program in Florida in October 2022 and Hawaii in 2023. DHRC members in Hawaii are continuing to work to improve program allocations in their state.
In October 2023, NLIHC in collaboration with NHLP released a report, “Plugging the Gaps: Recommendations for HUD’s RUSH Program,” in response to RUSH’s initial deployment. The report found that multiple problems combined to slow the implementation of RUSH-funded programs, from funds arriving well past the date on which they were expected, to the slow distribution of state allocated funds, to confusion about how disaster survivors could access the assistance provided by the program.
Read the DHRC and NHLP comment here.