With the passage of the American Rescue Plan, Congress allocated $5 billion in funding for Emergency Housing Vouchers. HUD’s Office of Public and Indian Housing (PIH) on May 5 published a notice entitled “Emergency Housing Vouchers – Operating Requirements” which describes HUD’s process for allocating approximately 70,000 emergency housing vouchers (EHVs) to public housing agencies (PHAs). The vouchers are designed to assist individuals and families experiencing homelessness, at risk of experiencing homelessness, or fleeing/attempting to flee, domestic violence, dating violence, sexual assault, stalking, or human trafficking. They also support those who were recently homeless and for whom providing rental assistance will prevent the family’s homeless or having high risk of housing instability.
The notice details procedures for PHAs receiving and administering EHVs. HUD’s allocation formula is designed to direct emergency vouchers to the PHAs operating in areas with the greatest need while also considering PHA capacity and the requirement to ensure geographic diversity, including rural areas. The EHV allocation formula will consider the following data and indicators to ensure that vouchers go to the PHAs with the greatest needs:
- Comparative Homeless and At-Risk of Homelessness Need
HUD will focus on “homeless need” and “at-risk of homeless need” for this indicator. They will be based on HUD’s Continuum of Care (CoC) Point-in-Time (PIT) homeless data and HUD’s tabulated data from the American Community Survey (ACS 2013-17) on rental households with incomes less than 30 percent of the Area Median Income (AMI).
- Geographic Diversity, Including Rural Areas
Since PHAs serving rural areas might have a relatively low absolute number of such individual and families due to the low population of the area in general, HUD’s formula also identities PHAs that operate in areas which have high rates of homelessness or at-risk of homelessness. The formula will ensure that at least one PHA operating in each area with these high homeless or at-risk of homelessness rates will receive an EHV allocation.
- PHA Agency Capacity
HUD’s allocation formula will consider two factors when determining the PHA’s capacity to implement this program effectively and quickly. The first, how many vouchers an agency currently administers within each county, and second, the PHA’s estimated leasing potential. PHAs that administer more vouchers relative to others in your country will have a greater need for EHV’s. PHAs that with Housing Choice Vouchers programs that are fully leased or almost fully leased are also assumed to have the operational capacity to take on a new allocation of vouchers.
- Base Formula Structure
All PHAs will be assigned a base formula allocation, which is estimated using a dual formula structure that provides the highest allocation of vouchers for a PHAS based on one of the following formulas:
- Formula A – Homeless Need Adjusted for PHA Capacity
- The estimated Homeless Need as described in paragraph (1) assigned to a PHA reduced by the PHA’s leasing potential divided by total Homeless Need less national leasing potential multiplied by the number of EHVs available to be allocated.
- Formula B- At- Risk of Homelessness Need Adjusted for PHA Capacity.
- At-risk Category 1: assigned to a PHA reduced by a PHA’s leasing potential divided by all PHA At-risk Category 1 less national leasing potential multiplied by 50 percent of EHVs available to be allocated plus.
- At-risk category 2: assigned to a PHA reduced by a PHA’s leasing potential divided by all PHA At-risk category 2 less national leasing potential multiplied by 50 percent of EHVs available to be allocated.
The formula that leads to a PHA has the having the highest number of EHV will be used. That assigned voucher allocation will be subject to a pro-rata reduction so that the total number of EHV’s that will be allocated to all PHAs is equal to the 70,000 vouchers.
- Minimum Allocation Size and Rural Area Adjustments
HUD will generally consider 25 vouchers to be the necessary minimum allocation size of the PHA to implement EHV’s but will make exceptions such as high-need rural areas. For areas (county 7 or group of counties) with high rates of homelessness or at-risk of homelessness populations, at least one PHA will receive an allocation of EHVs, even if no PHA met the minimum 25 voucher requirement. The PHA that is primarily operating in the high need area and to which the formula would allocate the largest allocation of EHVs will be allocated the greater of (1) the number of vouchers it received under the base formula or (2) 15 EHVs.
HUD will inform eligible PHAs of the number of EHVs they will be allocated by May 10th in which PHAs will have two weeks to accept or decline the offer for new vouchers. PHAs can choose to accept less than their max allocated vouchers. The notice goes into further detail on recapture and redistribution procedures.
EHV vouchers are incremental meaning that funding is allocated for EHV vouchers, renewal of these vouchers, and other fees associated with them. After September 30, 2023, a PHA cannot reissue them. Congress also granted HUD broad waiver authority with respect to the vouchers so there are a few key distinctions between regular HCVs and the new EHVs.
For an individual or family to be eligible for an EHV voucher, they must meet one of four eligibility categories:
- Homeless
- At risk of homelessness
- Fleeing, or attempting to flee, domestic violence, dating violence, sexual assault, stalking, or human trafficking
- Recently homeless and for whom providing rental assistance will prevent the family’s homelessness or having high risk of housing instability
NLIHC will inform Members and Partners when the allocation of the new vouchers is released and will provide a more in-depth analysis of the notice in the future.
For more information, read the PIH notice “Emergency Housing Vouchers – Operating Requirements” at: https://bit.ly/3upYxGo