Dear Secretary Carson:
We write concerning the Department of Housing and Urban Development's (HUD) Fiscal Year 2019 Notice of Funding Availability (NOFA). Specifically, we are alarmed by changes made to the Continuum of Care (CoC) Program competition which undermine the successful approach of Housing First and HUD's historic commitment to effectively serve transgender people experiencing homelessness. These changes invite discrimination and could result in trans people being denied access to critical homeless services, forcing them to remain on the street and putting them at further risk of physical violence and abuse. We strongly urge you to immediately reinstate the 2018 provisions of the CoC program.
Housing First has proven to be effective in quickly and successfully connecting people experiencing homelessness to housing without preconditions or barriers to entry, such as service participation requirements. This proven, evidence-based approach empowers people experiencing homelessness to rebuild their lives while promoting the efficient use of taxpayer dollars. Studies such as HUD's The Applicability of Housing First Models to Homeless Persons with Serious Mental Illness have confirmed these findings. As HUD Secretary, you have repeatedly expressed your support for the Housing First model, and recently stated before a crowd of nearly a thousand experts on homelessness that "the evidence then and now supports Housing First."
Through the CoC Program competition, HUD incentivizes housing providers to adopt a Housing First model by awarding points for adhering to Housing First polices. However, these incentives were removed in the 2019 NOFA, as were nearly all mentions of Housing First. The move away from voluntary, client-centered services defies common sense and will inevitably result in an increase in people experiencing homelessness. We strongly urge HUD to continue to emphasize the successful Housing First approach with its core components intact and to reinstate incentives for following the Housing First model.
Transgender Americans Experiencing Homelessness
People experiencing unsheltered homelessness face many dangers and are three times more likely to die than people living in shelters. The most effective responses to helping people experiencing unsheltered homelessness are based on a commitment to using local networks to promote outreach to the most vulnerable populations and operate with few, if any, barriers to shelter entry other than those necessary for the health and safety of shelter staff and other residents. This is especially true for trans people and the LGBTQ community more broadly, who disproportionately experience homelessness compared to the general population due to discrimination, violence, and family rejection. Close to one in three transgender and gender non-binary individuals will experience homelessness at some point in their lives. The situation is even more dire for LGBTQ individuals of color, where nearly half report experiencing homelessness.
Unfortunately, the 2019 NOFA removes all prior mentions of LGBTQ people, including key incentives to promote effective services to transgender people experiencing homelessness. While incentives remain for adherence to the general 2012 Equal Access rule, the removal of any mention of the 2016 Equal Access rule, which clarifies that the 2012 rule protects the right of transgender individuals to access shelter in accordance with their gender identity, is striking. In testimony before the House Financial Services Committee on May 21, 2019, you denied under oath that the administration had plans to scrap the 2016 Equal Access rule. The next day, however, HUD announced that the agency plans to propose a new rule that would allow federally funded shelter providers to discriminate against trans people experiencing homelessness by denying them access to critical homeless services based on their gender identity. This proposal, combined with the fact that the 2019 NOFA does not make a single reference to LGBTQ individuals, leads us to believe that HUD either does not understand the challenges and dangers that homelessness poses to the LGBTQ community or is knowingly discriminating against these individuals. Given the disproportionate number of trans people experiencing homelessness and the very real dangers they face as targets of violence and abuse, HUD must continue to require that homeless services providers do not discriminate against trans individuals who are seeking shelter.
Again, we strongly oppose these actions and we urge HUD to immediately reinstate the 2018 NOFA provisions to protect all people experiencing homelessness.