FEMA Changes Policy to Approve Non-Congregate Shelter Reimbursement for Duration of Emergency

NLIHC received confirmation from FEMA that the agency will approve reimbursement for non-congregate sheltering through its Public Assistance (PA) program for the “duration of the [COVID-19] emergency.”

This change will allow local and state officials to continue offering critical non-congregate sheltering programs needed to prevent and respond to coronavirus outbreaks among people experiencing homelessness and ensure non-congregate shelter residents can transition to permanent housing solutions when the pandemic recedes. This unprecedented decision was made thanks in part to the advocacy of the NLIHC-led Disaster Housing Recovery Coalition, a group of over 850 local, state, and national organizations working in the field of disaster recovery to ensure all disaster survivors are able to recover from disasters.

At the start of the pandemic, FEMA modified its PA guidelines to allow state and local governments as well as eligible non-profits to receive federal reimbursement for housing individuals experiencing homelessness in “non-congregate sheltering,” typically hotel rooms or other individual living arrangements. Congregate shelters – where large numbers of individuals share sleeping, eating, and bathroom arrangements – can facilitate the quick spread of coronavirus, placing shelter residents at high risk of infection, serious complications, and in worst cases death. FEMA reimbursements, provided at 75% of eligible costs, have allowed many states and cities to rapidly set up hotel room programs, helping to decrease overall shelter populations, prevent further spread of COVID-19, and ensure those most vulnerable to contracting the virus are safe.

Despite the success many areas of the country had in moving vulnerable individuals experiencing homelessness out of congregate shelter, FEMA program guidelines dictated that entities seeking federal reimbursement submit requests for reimbursement approval to FEMA regional administrators every 30 to 60 days. Without such approvals, entities conducting non-congregate sheltering are unable to seek reimbursement for eligible costs. This requirement has created a continuous threat of funding loss for non-congregate sheltering programs, as cash-strapped state and local governments are largely unable to fund such programs without federal assistance.

This rule change, first issued for California’s successful Project Homekey and Project Roomkey, no longer requires these periodic approvals. Instead, reimbursements for non-congregate sheltering will be approved nationwide until the national emergency ends. While the exact duration of the national emergency requires additional verification, the change will undoubtedly increase the stability of non-congregate sheltering programs across the country, allowing the programs to expand and improve without the threat of imminent cancellation of federal assistance.

Read an NLIHC best-practices document on non-congregate sheltering here: https://bit.ly/2LK08oQ

Read a press release on the change in California here: https://bit.ly/38jG7gC

Become a DHRC member and receive updates from the DHRC here: https://bit.ly/3p0ziY2