Updates on Treasury Emergency Rental Assistance Programs: Initial Trends from Tribal Nation Programs

NLIHC tracks all emergency rental assistance programs and shares best practices to ensure funds are equitably distributed. As of June 2, NLIHC has identified 390 rental assistance programs funded through the $25 billion appropriated for the Treasury Emergency Rental Assistance (ERA1) program under the December 2020 Consolidated Appropriations Act. Of these, 359 Treasury ERA programs are currently accepting applications, representing 50 states and DC, 155 counties, 50 cities, and 103 Tribal Nation programs. These programs represent over 66% of all grantees that received Treasury ERA funds and approximately $23.15 billion of the $25 billion allocation.  

Using publicly available information from program documents and websites, the NLIHC database includes comprehensive information on Tribal Nation ERA programs, including program design, implementation, and eligibility requirements. Of the 103 programs identified, 63% of programs have adopted tenant-initiated applications and cover both rent arrears and future payments, with 56% offering 12-15 months of assistance. Sixty-six percent of programs are administered by Tribally Designated Housing Entities (TDHEs, which in most cases were the direct grantees for federal assistance), while 34% are administered by Tribal Nation governments.

While tenant eligibility criteria remain consistent with other state and local ERA programs, most Tribal Nation programs also require that applicants either have some sort of tribal affiliation or rent on a reservation. Out of 103 Tribal Nation programs currently in the NLIHC database, 81% require some form of tribal enrollment card, citizenship certificate, a Social Security Number, or proof of renting on the reservation; 74% of programs specifically require households to have tribal descendants or an enrolled tribal member to qualify for assistance. Although most programs are open to any Tribal Nation citizen, programs vary based on proximity to reservation lands. Initial trends indicate that programs’ geographic reach depends on the capacity of the TDHE administering the program and the amount of funding received. With income eligibility for Treasury ERA determined using local AMI calculations, smaller Tribal Nation programs are restricting eligibility to Tribal Nation citizens within the reservation only. Conversely, larger programs with the capacity to incorporate varying AMI calculations into their application serve Tribal Nation citizens across the country.

Other trends from Tribal Nation ERA programs are similar to those observed in state and local programs. Nearly 47% of programs allow self-certification, most commonly when documenting financial hardship due to COVID. Most Tribal Nation programs do not allow direct-to-tenant payments; only 20% explicitly offer direct-to-tenant assistance. Further, only 23% of programs explicitly assist households receiving federal rent subsidies (e.g., Section 8/Housing Choice Vouchers).

NLIHC continues to monitor these trends weekly as programs open.