Testimony: Improving and Expanding CityFHEPS
Jennifer Hinojosa
Committee on General Welfare
Oversight - The CityFHEPS Rental Assistance Program
Testimony by: Jennifer Hinojosa
January 18, 2023
Thank you for this opportunity to comment on the issue of CityFHEPS rental assistance program. My name is Jennifer Hinojosa and I am a policy analyst at the Community Service Society. The Community Service Society is a 180-year-old independent nonprofit organization that addresses some of the urgent problems facing low-income New Yorkers and their communities, including citywide rising housing insecurity and homelessness.
Today, a record number of people are experiencing homelessness. According to the Department of Homeless Services, one year ago about 47,200 individuals were in a shelter.[1] Last week, about 70,500 people are in the city’s shelter system—an increase of 23,000 from this time last year. This is a 50% increase in a one-year span.
In addition, thousands more were living on the streets and subways or crowded into unsafe and precarious living conditions. Average shelter stays are incredibly long- ranging from 483 days for single adults to 773 days for families. Shelter to housing move out rates—appallingly low to begin with-- declined by 27 percent in the last fiscal year as the crisis deepened.
Given this background, we applaud the City Council and the Committee on General Welfare for convening this hearing on rental assistance in general and CityFHEPS in particular. While CityFHEPS can be a powerful tool against homelessness, the program is plagued with issues, including:
- Eligibility. Many households need CityFHEPS vouchers, yet strict rules limit who qualifies. To qualify for CityFHEPS, families have to navigate a maze of harsh and often contradictory requirements. Even for those who meet the complex criteria, the program is plagued by excessive delays. For example, advocates have long called to end the arbitrary “90-day rule” which requires most assistance seekers to spend a minimum of three months in a shelter before they become eligible. This rule takes a toll on families with young children whose lives are disrupted from repeated moves.
Our recommendation is to expand eligibility to more households, such as to families where everyone is undocumented. We appreciate the initiative, but we need more than just a resolution. It’s not enough.
The income and work requirement bill (or the intro bill T2023-2863 ) is a good first step but it is not comprehensive because other factors play a role - such as how long someone needs to stay in a shelter, immigration status, etc. So, we need something more holistic.
- Delays. Unfortunately, it often takes months for someone with a CityFHEPS voucher to secure and move into an apartment. Typos, missing documents, and other minor mistakes cause entire applications to be denied or delayed, which forces some households to stay in shelter for longer than they have to.
Our recommendation is to reform bureaucratic processes to make sure that the City and shelter staff quickly process applications and that minor errors no longer result in month-long delays or outright denials.
- Unfair rules. Unnecessary rules make it difficult for voucher holders to secure apartments. Under one rule, the city deducts a “utility allowance” from allowable rents, reducing the maximum rent a voucher holder’s apartment can charge, and limiting the apartments they can choose from. Another rule allows the city to reject apartments where the rent is deemed “unreasonable” in comparison to other rents in the immediate neighborhood. This comparison is late in the process, is not a legal requirement, and makes it extremely difficult for households to find apartments, particularly in a tight rental market.
Our recommendations is to eliminate the utility allowance and ease rent reasonableness rules.
- Discrimination. Many landlords do not want to accept vouchers, and therefore refuse to rent apartments to CityFHEPS households. This is called source of income (SOI) discrimination, which is illegal. Unfortunately, the City administration is failing to combat this problem. The NYC Human Rights Commission’s (CCHR) Source of Income Unit is supposed to represent voucher holders experiencing discrimination, but it currently has just four employees and grossly understaffed to protect peoples’ rights.
Our recommendation is to combat discrimination by rebuilding the City’s source of income discrimination unit and making sure that it has the capacity to enforce the rights of CityFHEPS voucher holders.
- Poor apartment conditions. The limited pool of apartments available to and accepting of voucher holders are often in decrepit conditions. Landlords tend to do less upkeep and outright neglect buildings where a majority of tenants have vouchers. This results in CityFHEPS households having to settle for substandard housing, particularly because there is nowhere, they can go to complain, and because it is difficult to move out and find other apartments.
Our recommendation to improve code enforcement by ensuring that oversight agencies regularly conduct thorough inspections, and that they have the capacity and expertise needed to enforce necessary repairs.
The Community Service Society of New York urges you to make the above changes to the CityFHEPs program as the number of homelessness individuals, families, and children are growing at alarming rates.
1. Source: NYC Shelter Count : City Limits