The Homeless Children and Youth Act, S.256, has sparked significant debate within the homelessness advocacy community, particularly concerning its proposed alterations to the Department of Housing and Urban Development’s (HUD) Continuum of Care program. While the Act aims to address the critical issue of housing instability among families and youth, organizations like the National Alliance to End Homelessness have voiced strong opposition. Their stance is not against aiding homeless youth and families, but rather against the specific mechanisms within S.256 that they believe would undermine the existing, and largely successful, Continuum of Care framework.
This article delves into the core arguments of those who oppose the proposed changes, focusing on why they believe the Homeless Children and Youth Act, in its current form, is detrimental to effectively combating homelessness. It examines the potential negative impacts on the Continuum of Care program, the concerns regarding resource allocation, and the practicality of the new mandates introduced by the bill. Understanding this opposition is crucial for anyone seeking to grasp the complexities of homelessness policy and the ongoing efforts to create effective solutions.
Overstretching Resources: The Danger of Redefining Homelessness
A primary concern for opponents of S.256 is the bill’s proposed expansion of the definition of homelessness. Currently, HUD’s definition encompasses individuals and families who are unsheltered, residing in homeless shelters, or temporarily “doubled up” with others but facing imminent displacement. The Homeless Children and Youth Act seeks to broaden this definition to include all impoverished families and youth living doubled up with others for economic reasons, regardless of the imminence of displacement.
This definitional shift, while seemingly compassionate, is seen as deeply problematic. The National Alliance to End Homelessness argues that this expansion would dramatically inflate the number of people eligible for HUD homeless assistance – potentially encompassing millions more individuals. This surge in eligibility would occur without any corresponding increase in funding for the Continuum of Care program.
The existing homeless assistance system is already under strain. It currently fails to reach nearly a third of those who are already defined as homeless, with 31 percent remaining unsheltered. Introducing millions of newly eligible individuals into this system without additional resources would inevitably dilute the effectiveness of the Continuum of Care program. Families, children, and unaccompanied youth in dire need of immediate shelter and support would face even greater hurdles in accessing assistance, as the system becomes overwhelmed by sheer volume.
Alternative Solutions: Focusing on Practical and Targeted Support
Instead of broadening the definition of homelessness and straining an already burdened system, opponents advocate for alternative approaches that address the root causes of housing instability and provide more targeted support.
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Addressing Housing Affordability: Many families and youth who are doubled up due to economic hardship are not literally homeless, but they are facing severe housing insecurity. Their primary need is affordable housing solutions, not necessarily homeless services. Policy proposals focused on expanding housing vouchers, developing affordable housing units, and implementing tools like short-term housing subsidies or renter tax credits are seen as far more effective in addressing this underlying issue.
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Removing Barriers to Access for the Literally Homeless: For those who are genuinely homeless and doubled up – meaning they are facing imminent displacement – navigating the homeless assistance system can be challenging. Documenting their homelessness can be a significant hurdle. Opponents suggest loosening documentation requirements for doubled-up individuals who are verifiably homeless (facing displacement within 14 days). It’s important to note that crisis services like emergency shelter already have less stringent documentation requirements, and this streamlining should be extended to those seeking longer-term housing solutions like rapid re-housing or permanent supportive housing.
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Strengthening Rural Homeless Assistance: In rural areas, the lack of homeless shelters and facilities often forces homeless individuals to double up with others. The HEARTH Act authorized a rural homelessness program specifically to address these unique challenges. Advocates urge HUD to prioritize the implementation and funding of this rural program to better serve geographically isolated homeless populations.
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Recognizing the Unique Needs of Youth: Unaccompanied youth under 18 living in precarious housing situations require specific consideration. Regardless of the duration of their stay, if they are in a household without a responsible adult or are at risk of victimization, they should be considered homeless. Opponents suggest revising the 14-day imminence of eviction requirement for this vulnerable population. Furthermore, there is a call for clearer delineation of responsibility, with the Department of Health and Human Services (HHS) taking primary responsibility for unaccompanied minor youth and HUD focusing on housing support.
The Burden of Data Collection: A Costly and Questionable Mandate
Another significant point of contention is the bill’s mandate for communities to conduct ongoing assessments of the number of poor families and youth who are doubled up for economic reasons – the very population the bill seeks to newly define as homeless. While accurate data is crucial for effective policymaking, opponents argue that this specific data collection requirement is impractical, costly, and ultimately of questionable value.
HUD already requires communities to perform a biennial Point-in-Time (PIT) count of literally homeless individuals. However, HUD’s authorizing legislation explicitly advises against including doubled-up individuals in this count due to the immense difficulty and expense of accurately capturing this population. S.256, in contrast, would require annual counts of doubled-up poor families and youth.
Conducting such counts would necessitate expensive new census efforts, surveys, or sampling studies at the local level. The bill, however, provides no funding to offset these costs, placing a significant financial burden on local jurisdictions. Furthermore, given that the majority of doubled-up families and youth are not literally homeless and their primary need is affordable housing, the rationale for this costly and complex annual count is questioned.
Alternative Data Strategies: Leveraging Existing Resources and Targeted Research
Instead of imposing a burdensome and potentially inaccurate data collection mandate, opponents propose leveraging existing data resources and focusing on more targeted research approaches.
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Utilizing Census Bureau Resources: The U.S. Census Bureau is the ideal entity for large-scale population surveys. There is a recognized need to better understand the size of the doubled-up population that is truly homeless. HUD already assesses the broader doubled-up population by Census Tract through its biennial American Housing Survey (AHS), conducted by the Census Bureau. In 2013, an AHS Doubling-Up Module was tested to identify doubled-up households containing homeless individuals. Making this module a permanent feature of the AHS would provide valuable data for HUD to understand the scope of the problem without requiring costly new local surveys.
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Supporting Ongoing Youth Homelessness Research: Several national research initiatives are already underway to improve the measurement of youth homelessness, including studies by Chapin Hall. These efforts will provide valuable insights into the size of the youth homeless population and refine counting methodologies. Supporting and leveraging these existing research efforts is a more efficient and effective approach than mandating new, potentially duplicative local counts.
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Testing the Feasibility of Local Surveys: Before implementing a universal and costly mandate, HUD could pilot test the viability of local counts of doubled-up youth and families. This could involve offering communities the opportunity to voluntarily conduct counts, providing guidance on survey methodologies, and offering technical assistance. Data from these pilot counts, properly attributed, could be included in HUD’s Annual Homeless Assessment Report (AHAR), allowing for an evaluation of the viability and usefulness of such local counts before widespread implementation.
Undermining Strategic Resource Allocation: Jeopardizing Program Effectiveness
A critical concern among opponents is that the Homeless Children and Youth Act would hinder HUD’s ability to strategically allocate resources within the Continuum of Care program. Over the past decade, the HUD homeless program has achieved significant success in reducing homelessness, largely attributed to its focus on evidence-based practices, outcome-based approaches, and the collaborative partnership between federal administration and local innovation. This successful combination has led to demonstrable decreases in homelessness among both families and single adults. (While homeless youth have a dedicated funding stream at HHS, they have been a secondary focus for HUD).
S.256, by expanding the eligible population and restricting HUD’s ability to set national priorities or link evidence-based interventions to specific populations, is seen as a threat to this hard-won progress. Diluting the program’s focus and impact by serving a vastly expanded population without increased resources could make it impossible to discern outcomes and potentially lead to a decline in federal support for the program.
Alternative Strategies: Ensuring Strategic and Equitable Resource Distribution
Instead of dismantling HUD’s strategic approach, opponents advocate for ensuring that resource allocation remains strategic while also addressing the needs of all homeless subpopulations equitably.
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Employing Proportionality within HUD’s Housing Focus: HUD’s resources should be distributed fairly across homeless subpopulations, considering their need for housing interventions – HUD’s core area of expertise. This can be achieved not by removing HUD’s strategic controls, but by requiring HUD to maintain proportionality between resources and the needs of different homeless subpopulations. Currently, there is approximate proportionality for most populations, including families and youth. However, non-disabled individuals, including youth aged 18-24, often receive less than their proportional share of resources. Adjustments to ensure fairer distribution within existing strategic frameworks are preferable to abandoning strategic allocation altogether.
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Clarifying and Enforcing Responsibility Across Federal Agencies: Concerns remain about whether homeless youth under 18 receive proportional resources. Advocates reiterate the need for HHS to assume primary responsibility for unaccompanied minor youth, allowing HUD to focus its housing resources strategically. Clearer inter-agency collaboration and accountability are crucial to ensuring comprehensive support for all vulnerable populations.
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The existence of homeless children and youth is a deeply troubling issue. The lack of comprehensive understanding of the scope of the problem, particularly concerning doubled-up homeless families and youth, is a significant challenge. And the reality that many children and youth are unable to access the help they desperately need is unacceptable.
The Homeless Children and Youth Act (S.256) raises these critical issues, highlighting genuine problems within the current system. However, opponents argue that the Act, in its current form, is not the solution. Instead of expanding the definition of homelessness in a way that strains resources and undermines effective programs, the focus should be on counting and serving literally homeless families and youth more effectively, removing practical barriers to their access to assistance, and providing robust housing assistance to those who are housing insecure but not literally homeless. HUD’s continued leadership and strategic allocation of homeless resources are essential to effectively address homelessness and ensure that effective strategies are deployed to end homelessness for all literally homeless individuals as quickly as possible.
The line defining homelessness can be debated. However, expanding the definition to include millions more people without a corresponding increase in resources is not progress. Organizations like the National Alliance to End Homelessness remain deeply committed to ending family and youth homelessness, and homelessness overall. They advocate for continued dialogue and collaboration to identify and implement the most effective approaches to achieve this critical goal.
