NLIHC Joins Comment Letter to HUD on Implementation of VAWA Policies

NLIHC, along with 35 other national, state, and local organizations, joined a January 3 comment letter to HUD providing guidance on the implementation of the reauthorized “Violence Against Women Act” (VAWA). The letter, led by the National Housing Law Project and Housing Justice Network, was written in response to an Information Collection Notice issued by HUD requesting public comments on HUD’s emergency transfer reporting and data collection policies for covered housing providers; model emergency transfer policies; family break-up and lease bifurcation policies; and lease addendums.

First enacted in 1994, VAWA creates and supports comprehensive resources to respond to the needs of survivors of sexual violence, domestic and dating violence, stalking, and human trafficking. The law is reauthorized every five years to update the legislative text with new best practices and build on existing protections and programs to better meet the needs of survivors. Most recently, the “VAWA Reauthorization Act of 2022” was included in the fiscal year (FY) 2022 omnibus spending package enacted in March 2022.

Among other suggestions, the letter urges HUD to ensure all VAWA forms and information meet language access requirements for people with disabilities and for people with limited English proficiency. Comments also emphasized HUD’s need to ensure every VAWA implementation form provides consistent information to survivors on resources and services available in their communities. Moreover, the letter suggests HUD should provide clear directions for housing providers on connecting survivors of violence to victim service providers and culturally specific organizations. These organizations offer vital services to survivors, including safety planning, in which a service provider works with a survivor to develop a plan to exit an abusive situation in a way that reduces the survivor’s risk of harm.

Additionally, the letter emphasizes the necessity of confidentiality and safe communications between survivors and covered housing providers, including prohibiting the sharing of personally identifying information about survivors without the informed, time-limited, written consent of the survivor. Covered housing providers who violate the confidentiality rules should be penalized. The comments also provide suggestions for how HUD should revise its emergency transfer, lease bifurcation, and family break-up policies, which are essential for helping survivors leave an abusive situation without losing their housing assistance.

Read the comment letter at: