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The Network Submits Comment to HUD’s “Verification of Eligible Status” Proposal


The Network’s letter explained how the “mixed status rule” would negatively affect New York, the supportive housing community, and the homelessness crisis.

Screenshot from page showing National Archives logo and Housing and Community Development Act of 1980: Verification of Eligible Status text

On July 8, 2019, on behalf of New York’s supportive housing community, the Network submitted comment to the Department of Housing and Urban Development (HUD) expressing strong opposition to the changes regarding “verification of eligible status,” published in the Federal Register on May 10, 2019. The Network’s letter outlined with specifics how the proposed rule “would only exacerbate the homelessness crisis plaguing the nation.”

A high-level view of its content is below.

The Proposed Rule Will Limit the Quantity of Subsidies and Increase Homelessness in New York City

  • Because mixed status families receive a prorated subsidy for only eligible family members, fewer, not more, families are likely to receive assistance, despite the rule’s stated intent to address the waitlist crisis faced by Public Housing Authorities nationwide; this is by HUD’s own analysis.
  • More families, particularly families with children, will enter the shelter system after years of being stably housed, a cost that HUD will likely have to subsidize; the financial impact on HUD will be severe.

In essence, this proposed rule, which aims to limit financial resources to noncitizens, is antithetical to its own philosophy.

The Proposed Rule Will Have an Adverse Effect on Citizen Children’s Stability

  • 5,700 children in New York City could be evicted from their homes and potentially become homeless, a serious risk given that child homelessness is associated with an 87% greater likelihood of a child or youth dropping out of school.

We need policies that expand, not reduce, access to stable homes for families with children in order to ensure all children have opportunities to be healthy and reach their highest potential.

The Proposed Rule Will Hurt U.S. Citizens and the Formerly Homeless Population

  • The proposed documentation requirements will be particularly burdensome for recipients of rental assistance who were formerly homeless, as well as for people experiencing homelessness who could be assisted by Section 214 programs in the future.

The Proposed Rule Creates an Administrative Burden on Public Housing Agencies and Housing Providers

  • Under the proposed new requirement for documentation, the New York City Public Housing Agency (NYCHA), which houses nearly 400,000 residents, as well as supportive housing providers with tenants utilizing project based or housing choice vouchers, would face significant increase in cost burdens. These constitute yet another cost in the proposed rule not offset by the benefit of reduced waitlists or improvements to the public housing stock.

We urge HUD to immediately withdraw its current proposal, and dedicate its efforts to advancing policies that strengthen the ability of immigrants to support themselves and their families in the future. If we want our communities to thrive, everyone in those communities must be able to stay together and get the care, services, and support they need to remain healthy and productive.

Click to read the Network’s letter.

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