NLIHC Releases New Report on Fact-Specific Proxy Implementation in ERA Programs

NLIHC released a new report, Implementing Fact-Specific Proxy in ERA Programs: Key Considerations and Lessons Learned, on February 17. The report examines the use of fact-specific proxies in U.S. Department of the Treasury (Treasury) Emergency Rental Assistance (ERA) programs. Fact-specific proxies reduce documentation barriers to ERA by allowing programs to infer an applicant’s income using facts such as the median income of the applicant’s census tract. Instead of being required to provide documentation proving their income, applicants meeting proxy eligibility criteria need only to self-attest to their household income. Focusing on nine programs that utilize fact-specific proxies, the report discusses federal guidelines regarding fact-specific proxies, considerations for implementing them, the impacts of fact-specific proxies on program progress, and lessons that can be learned from recent implementation efforts.

ERA guidance did not include fact-specific proxy as an allowable form of income verification until May 7, 2021, five months after Treasury released its initial guidance. The May 7 guidance stated that grantees could use a reasonable proxy, such as average incomes in a neighborhood, in conjunction with self-attestation – a written attestation of an applicant’s income without additional documentation – to determine household incomes. According to NLIHC research, by the end of 2021, 26 programs were using fact-specific proxy for income determination.

The report finds that programs were motivated to implement fact-specific proxies in order to increase application accessibility, enhance program equity, and balance program flexibility and oversight. Fact-specific proxies also helped programs decrease application processing times, increase fund disbursal, and decrease administrative burden for applicants.

The report highlights several lessons learned for programs considering using fact-specific proxy in the future. For example, 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 also found that program administrators who championed their innovations helped more risk-adverse programs feel comfortable implementing fact-specific proxy. 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.

To learn more, read the report at: https://bit.ly/34H9jk0