Institute for Policy Integrity

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Letter to HUD on Homelessness

January 18, 2012

The Dept. of Housing and Urban Development has issued two proposals that would significantly alter the way the government handles homelessness and institute major improvements to the agency’s work; Policy Integrity recently submitted a letter on both.

One proposal, named the Emergency Solutions Grant (ESG) program, would shift the focus of government programs away from providing short-term emergency housing toward providing long-term homelessness prevention. The other proposal would improve HUD’s Homeless Management Information Systems (HMIS) and related procedures for collecting and tracking data related to homelessness.

The letter guides HUD in evaluating the performance of its restructured ESG program, with an eye toward sponsoring the collection and analysis of relevant data at the local and national levels. Our recommendations include using evidence-based decision-making to evaluate ESG grants and funded programs, in line with the requirements of the Homeless Emergency Assistance and Rapid Transition to Housing Act of 2009 (HEARTH Act), under which both proposals are being promulgated.

HUD is modifying the HMIS regulations in order to require the collection of new information; this update will help ensure that HMIS is the central repository for all information about homeless individuals who participate in a “continuum of care,” meaning that they receive various types of public aid related to their housing, such as rental assistance along with other social services. The letter recommends that HUD modify the regulations to providing additional encouragement guidance for local data collection and to requiring the collection of both pre-intervention and post-intervention data in order to better monitor the long-term effects of ESG funded programs.

Furthermore, the regulations should be modified to enhance the ability of localities to link up their databases and to share information with researchers; this is necessary so that researches do not need to rely solely on self-reporting by clients of homelessness prevention programs for data collection. HUD should also implement standards for national data collection to facilitate nationwide research on homelessness prevention and to provide a more user-friendly and information-rich framework for analysis—as it stands, current regulations require to obtain HMIS data from individual local studies.

Filed under Letters, Safety and Consumer Protection