NLIHC Sends Letter to Treasury Calling for Additional ERA Reallocation Guidance

NLIHC President and CEO Diane Yentel sent a letter on November 4 to U.S. Department of the Treasury Secretary Janet Yellen, HUD Secretary Marcia Fudge, and White House Senior Advisor Gene Sperling, urging Treasury to issue further guidance on the Emergency Rental Assistance (ERA) reallocation process to ensure resources are allocated equitably. The letter pushes Treasury to hold renters harmless for the inefficiency and slow spending of some ERA programs.

Treasury issued on October 4 guidance on reallocating the $25 billion in ERA appropriated under the Consolidated Appropriations Act of 2021, referred to as “ERA1” (see Memo, 10/12). The letter outlines several key recommendations for further guidance that would ensure the reallocation process aligns with the intent of the ERA program – to keep low-income renters stably housed amid a public health and economic crisis. The recommendations were developed with direct input from local advocates and organizations working to ensure ERA reaches renters who face the greatest risk of eviction.

While Treasury’s current guidance seeks to hold renters harmless for low-performing programs, additional guidance is needed to ensure reallocation decisions are based on a balance between spending resources quickly, meeting the needs of low-income renters, and retaining renters’ access to emergency aid when funds are moved across program jurisdictions. The letter urges Treasury to make reallocation decisions based on the needs of renters and people experiencing homelessness, and not solely on the ability of programs to distribute aid quickly. NLIHC recommends Treasury take several key actions before reallocating funds out of poor-performing states and localities with high needs to ensure renters and landlords are not left without aid due to where they live.

The letter outlines recommendations for Treasury’s redistribution formula to ensure resources reach households with the greatest needs, not just renters in high-performing jurisdictions. Such recommendations include incorporating need-based measures in the formula, conducting an equity analysis, and using the recapture and reallocation process to address inequities in the original ERA allocation formula. NLIHC urges Treasury to strengthen and enforce its program improvement plan provisions to hold ERA grantees accountable and ensure they adopt best practices to improve the delivery of aid. The letter calls on Treasury to increase data transparency and oversight to allow policymakers, researchers, and advocates to identify and better understand gaps in program design and opportunities for policy improvements.

Read the letter at: