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NLIHC Submits Comments on MTW Expansion

NLIHC offered comments in response to HUD’s request for recommendations for specific policy proposals to be implemented as part of the expansion of the Moving to Work (MTW) demonstration (see Memo, 4/4).

The “Consolidated Appropriations Act of 2016” authorizes HUD to expand the MTW demonstration program by an additional 100 public housing agencies (PHAs) over a period of seven years (see Memo, 12/21/15). PHAs will be added to the MTW demonstration by cohort, each of which will be overseen by a research advisory committee to ensure the demonstrations are evaluated with rigorous research protocols. Each year’s cohort of MTW sites will be directed by HUD to test one specific policy change.

HUD asked for recommendations regarding work requirements, time limits, and alternative rent-setting methods. NLIHC has long opposed such MTW policies because of the potential harm to residents.

NLIHC wrote that if work requirements are permitted for one of the cohorts, the demonstration should consider the type and level of training or preparation, job search assistance, and child care needed and provided. Wages and benefits, hours worked per week, and job turnover should be monitored and reported for three to five years. In order to compare outcomes among cohort PHAs, the job market for the type of employment likely to be available to residents should be assessed and reported each year. There should be provisions to protect residents who encounter temporary layoffs through no fault of their own.

NLIHC recommends that the demonstration track for three to five years any household subject to a work requirement that is displaced through no fault of their own, recording whether the displaced household’s replacement home meets Housing Quality Standards (HQS), causes the household to be cost burdened or severely cost burdened, and is located in a racially or ethnically concentrated area of poverty. The evaluation should also record the number of times the household moves during the study period, any period of homelessness, and the impact of such housing instability on the educational attainment and physical health of any children in the household. PHAs should also be required to report the composition of families affected (i.e. family size, family member with a disability, etc.)

If time limits are permitted for one of the cohorts, NLIHC recommends that the demonstration track for three to five years households displaced due to the policy, recording the same information described for displacement due to work requirements.

If a cohort is allowed to experiment with alternative rent-setting methods (such as higher minimum rents, flat rents that do not adjust downward when a household’s income declines, tiered rents unrelated to household income, and shallow subsidies that result in households spending more than 30% of their income for their federally-assisted homes) NLIHC recommends the demonstration track the impact on households for three to five years, assessing changes in household expenditures for essentials such as food and healthcare. If an alternative rent-setting policy causes a household to leave public housing or the voucher program in order to lower their housing costs, the demonstration should track the household for three to five years, recording the same information described for displacement due to work requirements and time limits

Households displaced due to MTW waivers should be provided with relocation assistance, including housing search assistance and help finding housing in areas of higher opportunity. In addition, the PHA should pay for the household’s moving costs, including costs such as utility hook ups and advance rent payments required by the landlord. PHAs should report the costs of implementing and monitoring a time limit policy annually.

NLIHC recommends increasing the percentage of an MTW agency’s voucher allocation that may be used to project base vouchers (PBV) from 20% to 35% if the extra 15% is used to project base vouchers in areas of high opportunity or in areas that are gentrifying or are at risk of gentrifying, or when the PBV preserves existing affordable housing in other areas if that housing is at risk of leaving the affordable stock. Increasing or preserving the stock of housing affordable to extremely low income households through augmented PBV capacity can help offset the difficulty many voucher holders experience in utilizing their voucher due to landlords’ reluctance or refusal to accept vouchers.

To help low income families move to high-opportunity neighborhoods, NLIHC recommends allowing MTW agencies to set payment standards at levels that reflect market rates up to a maximum of 140% of the fair market rent.

NLIHC recommends that the research and evaluation of the new MTW agencies must ensure that they comply with the statutory language that requires PHAs substantially serve the same number of families and maintain a comparable mix of families by family size as would have been assisted prior to the MTW designation. The evaluations should also ensure that, as required by the authorizing statue, at least 75% of the families assisted have incomes less than 50% of the area median income (AMI), and as required by the Quality Housing and Work Responsibility Act of 1998, 75% of new voucher households and 40% of new public housing households have incomes less than 30% of AMI.

NLIHC’s comment letter is at: